GAO-25-107067: Small Business Pilot Program: SBA Has Opportunities to Evaluate Outcomes and Enhance Fraud Risk Mitigation
Summary
GAO-25-107067, Small Business Pilot Program: SBA Has Opportunities to Evaluate Outcomes and Enhance Fraud Risk Mitigation, a March 2025 Government Accountability Office report to congressional requesters. It reviews SBA's Community Navigator Pilot Program, directed by the American Rescue Plan Act of 2021, which operated from December 2021 to May 2024 and awarded grants to hubs that partnered with smaller organizations called spokes. GAO reports that SBA data suggest the program served a higher proportion of clients from high-minority, high-poverty and low-income areas than other SBA business assistance programs. It states that SBA does not plan to evaluate outcomes of the pilot. GAO recommends an evaluation of the program and procedures to obtain information from district offices in competitive grant reviews.
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“GAO-25-107067: Small Business Pilot Program: SBA Has Opportunities to Evaluate Outcomes and Enhance Fraud Risk Mitigation.”
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United States Government Accountability Office
Report to Congressional Requesters
SMALL BUSINESS
March 2025
PILOT PROGRAM
SBA Has
Opportunities to
Evaluate Outcomes
and Enhance Fraud
Risk Mitigation
GAO-25-107067
March 2025
SMALL BUSINESS PILOT PROGRAM
SBA Has Opportunities to Evaluate Outcomes and
Enhance Fraud Risk Mitigation
Highlights of GAO-25-107067, a report to
congressional requesters
Why GAO Did This Study What GAO Found
Racial and ethnic minorities, women, The Small Business Administration’s (SBA) Community Navigator Pilot Program
tribal groups, and other communities aimed to expand access to small business assistance resources for underserved
have historically faced barriers to communities. The program, which operated from December 2021 to May 2024,
accessing credit, capital, and other awarded grants to “hubs”—nonprofits, local governments, and other entities that
resources necessary to start and grow partnered with smaller organizations, called “spokes” (see figure).
businesses, according to SBA. The
American Rescue Plan Act of 2021
Overview of SBA Community Navigator Pilot Program
directed SBA to establish the
Community Navigator Pilot Program, a
new, short-term business assistance
program to serve these communities.
GAO was asked to review the
Community Navigator Pilot Program.
This report examines (1) how the
program reached underserved small
business owners, (2) the program’s
alignment with leading practices for
pilot program design, and (3) the SBA data suggest the program served a higher proportion of clients from high-
program’s efforts to manage fraud risk. minority, high-poverty, and low-income areas compared to other SBA business
assistance programs. Challenges that navigators identified included collecting
GAO analyzed SBA documents,
interviewed officials, and compared the
sensitive client data and building effective partner networks.
pilot program design and fraud risk The Navigator Program aligned with one and partially aligned with four leading
management processes against practices for pilot program design. SBA established clear, measurable program
leading practices. GAO also analyzed objectives, such as increasing use of SBA services among underserved business
SBA and Census data and interviewed owners, and developed a data gathering strategy and assessment methodology.
18 navigators (chosen to reflect a mix
of grant amounts, regions, and However, GAO identified opportunities for SBA to evaluate the pilot and mitigate
organization types) about their broader program risks:
activities. GAO conducted three site
visits reflecting a mix of geographic • Evaluation. SBA does not plan to evaluate outcomes of the pilot. However,
regions and organization types. evaluations play a key role in strategic planning and program management.
Conducting an evaluation would capture lessons learned from pilot activities.
What GAO Recommends Additionally, by assessing scalability and incorporating input from a broad
array of SBA staff and partner organizations, the evaluation could inform
GAO recommends that SBA (1)
current and future programs and congressional decision-making.
evaluate the Navigator Program,
incorporating a scalability assessment • Fraud mitigation. SBA took steps to address fraud risk for the program,
and input from a broad array of SBA such as completing a fraud risk assessment and training hubs on financial
staff and partner organizations; and (2) oversight. However, during application reviews, SBA staff did not consult
implement procedures for competitive local SBA offices with potential knowledge about applicants’ risks. For
grant program application reviews to example, staff in one district office said they could have flagged a local
obtain relevant information from district applicant that overstated its capacity to provide assistance. SBA officials said
office staff with knowledge of that to avoid potential bias and inconsistency, its competitive grant programs’
applicants. SBA agreed with both application reviews do not include consultation with local SBA offices.
recommendations. However, GAO identified federal grantmaking agencies that incorporated
local staff input while implementing safeguards to mitigate bias and maintain
For more information, contact Jill Naamane, consistency. By developing procedures to obtain relevant information from
NaamaneJ@gao.gov.
local agency staff, SBA could improve its ability to assess applicants and
address fraud risks.
United States Government Accountability Office
Contents
Letter 1
Background 3
Navigators Provided Training and Counseling to Underserved
Small Business Owners, and Noted Benefits and Challenges 7
Navigator Program Partially Aligned with Most Leading Practices
but No Outcome Evaluation Is Planned 20
SBA Took Steps to Mitigate Navigator Program Fraud Risks but
Did Not Solicit District Staff Input on Applicants 25
Conclusions 33
Recommendations for Executive Action 33
Agency Comments and Our Evaluation 34
Appendix I Objectives, Scope, and Methodology 37
Appendix II Demographic Analysis of Counseling Clients in Selected
SBA Programs 47
Appendix III Comments from the Small Business Administration 48
Appendix IV GAO Contact and Staff Acknowledgments 50
Tables
Table 1: Counseling Hours and Number of Clients SBA’s
Community Navigator Pilot Program Reported for Clients
Who Self-Identified with Targeted Groups 9
Table 2: Percentages of Counseling Clients by Zip Code
Characteristics for Selected SBA Programs 11
Table 3: Client-Hours of Service Selected SBA Programs
Reported Providing in Fiscal Years 2022 and 2023 13
Table 4: Description of Fraud Risks and Control Activities SBA
Identified for the Community Navigator Pilot Program’s
Fraud Risk Assessment 26
Table 5: Demographic Attributes Reported by Counseling Clients
of Selected SBA Programs in Fiscal Years 2022 or 2023 47
Page i GAO-25-107067 Small Business Pilot Program
Figure
Figure 1: SBA’s Competitive Grant Application Review Stages for
Hubs in the Community Navigator Pilot Program 29
Abbreviations
ARPA American Rescue Plan Act of 2021
COMNAVS Community Navigator Information Management
System
EDMIS-NG Entrepreneurial Development Management
Information System-Next Generation
LGBTQ+ lesbian, gay, bisexual, transgender, or queer
OMB Office of Management and Budget
SBA Small Business Administration
SBDC Small Business Development Center
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Page ii GAO-25-107067 Small Business Pilot Program
Letter
441 G St. N.W.
Washington, DC 20548
March 27, 2025
Congressional Requesters
Certain communities have historically faced barriers to accessing credit,
capital, and other resources necessary to start and grow businesses,
according to the Small Business Administration’s (SBA) Council on
Underserved Communities. These communities may include populations
such as American Indians or Alaska Natives, women, racial and ethnic
minorities, veterans, and those living in inner cities or rural areas. 1 SBA’s
business assistance programs offer training, counseling, networking, and
mentoring services to current or prospective small business owners,
including those who belong to these communities.
The American Rescue Plan Act of 2021 directed SBA to create the
Community Navigator Pilot Program, a short-term business assistance
initiative designed to support recovery from the economic downturn
caused by the COVID-19 pandemic. 2 The statute identified historically
underserved small business owners as the program’s focus, although all
current or prospective small business owners could access its services.
SBA selected organizations for grant awards under the program in
October 2021 and established a 2-year performance period (December
2021–November 2023). It then offered a 6-month extension for
organizations with remaining funds and ended the program in May 2024.
You asked us to review SBA’s implementation of the Navigator Program.
This report examines (1) how and the extent to which the program
reached underserved small business owners, (2) the program’s alignment
with leading practices for pilot program design, and (3) the program’s
efforts to manage fraud risk.
For the first objective, we obtained and analyzed SBA client-level data on
services provided through the Navigator Program and the demographic
1SBA’s Council on Underserved Communities webpage refers to tribal groups.
Throughout this report, we refer to individuals who self-identified as American Indian or
Alaska Native to reflect the information available in the SBA data we analyzed. The
agency data did not include information about whether these individuals were tribal
citizens or resided on reservations.
2Pub. L. No. 117-2, § 5004, 125 Stat 4, 91 (codified at 15 U.S.C. § 9013). The statute
required SBA to obligate Navigator Program funds by the end of fiscal year 2022 and
expend the funds by the end of calendar year 2025.
Page 1 GAO-25-107067 Small Business Pilot Program
composition of clients it served. 3 We also obtained similar data for three
other SBA business assistance programs and used SBA and U.S.
Census Bureau data to compare clients by zip code characteristics
between the Navigator Program and these programs. 4 We calculated the
total client-hours of training and counseling services and the estimated
cost per client-hour of services delivered for each program during
specified periods. We interviewed representatives from a
nongeneralizable sample of 18 organizations that participated in the
Navigator Program to describe how they reached underserved small
business owners. These organizations were selected to reflect a mix of
grant amounts, geographic regions, and other factors. They included
nonprofits, local governments, and other entities. We conducted some of
these interviews during three site visits reflecting a mix of geographic
regions and organization types.
For the second objective, we reviewed documentation that included the
program’s notice of funding opportunity and implementation plan, and
SBA’s evaluation of the program’s implementation. We compared the
Navigator Program’s design against leading practices for pilot program
design we have previously identified. 5
For the third objective, we reviewed the fraud risk assessment SBA
conducted for the program and the agency’s Standard Operating
Procedure for Grants Management, guidance for staff, and training for
organizations that received grant awards. We also reviewed selected
documentation from a nongeneralizable sample of 10 grant files.
For all three objectives, we interviewed SBA staff on program design and
evaluation, data collection, and fraud mitigation. More detailed information
on our objectives, scope, and methodology is presented in appendix I.
We conducted this performance audit from September 2023 to March
2025 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
3SBA refers to individual businesses, current or prospective, as clients.
4The three other SBA business assistance programs were the Small Business
Development Center (SBDC), Women’s Business Center, and SCORE programs. We
chose these three programs because they provide services similar to the Navigator
Program and used SBA’s Entrepreneurial Development Management Information System-
Next Generation (EDMIS-NG) to store data on their clients’ characteristics.
5GAO, Data Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet Goal of
Reducing Recipient Reporting Burden, GAO-16-438 (Washington, D.C.: Apr. 19, 2016).
Page 2 GAO-25-107067 Small Business Pilot Program
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.
Background
SBA Business Assistance SBA’s Office of Entrepreneurial Development aims to help small
businesses start, grow, and compete in global markets by providing
training, counseling, and access to resources. The office oversaw the
Navigator Program. It is also responsible for overseeing SBA’s other
business assistance programs, referred to as SBA resource partner
programs. These include the Small Business Development Center
(SBDC), Women’s Business Center, and SCORE programs. SBA’s Office
of Veterans Business Development oversees the Veterans Business
Outreach Center program, which is also an SBA resource partner
program. 6
Through these programs, SBA provides technical assistance with
preparing and assembling documents small business owners need to
apply for small business loan and assistance programs. These
documents can include tax records, bank statements, profit and loss
statements, and business plans. According to an SBA Information Notice,
collecting these documents and completing program applications without
assistance can be challenging for small business owners. 7 These
challenges can also be more significant for small business owners from
minority, immigrant, rural, and other underserved communities, or those
with disabilities.
The SBDC and SCORE programs were designed to serve all small
business owners without targeting specific groups. In contrast, the
Navigator Program targeted underserved communities, the Women’s
Business Center program targets women entrepreneurs, with an
emphasis on socially and economically disadvantaged entrepreneurs,
6SBA resource partners are organizations that provide services through SBA funding or
through another recognized relationship with the SBA. We refer to organizations
participating in these resource partner programs as SBDCs, Women’s Business Centers,
SCORE chapters, and Veterans Business Outreach Centers. Despite its capitalization, the
term SCORE is not an acronym, but rather the official program name.
7U.S. Small Business Administration, Information Notice: Use of Community Navigators to
Provide Technical Assistance, Control No. 6000-806503 (Washington, D.C.: Mar. 2021).
Page 3 GAO-25-107067 Small Business Pilot Program
and the Veterans Business Outreach Center program targets veteran and
military entrepreneurs.
Navigator Program In accordance with the American Rescue Plan Act of 2021, the Navigator
Targeted Outreach Program aimed to expand awareness and increase use of existing SBA
services among underserved small business owners, with a focus on
women, veteran, and socially and economically disadvantaged small
business owners. 8 SBA’s May 2021 notice of funding opportunity for the
program identified 10 groups for targeted outreach:
• COVID-19 affected businesses 9
• Socially and economically disadvantaged small businesses
• Minority entrepreneurs
• Microbusinesses 10
• Women entrepreneurs
• Rural entrepreneurs
• Entrepreneurs with disabilities
8Section 5004 of the American Rescue Plan Act of 2021 (ARPA) provides that any small
business concern is eligible for community navigator services, with priority for small
business concerns owned and controlled by women or veterans, and socially and
economically disadvantaged small business concerns as defined in the Small Business
Act. The Small Business Act defines the term “socially and economically disadvantaged
small business concern” to mean any small business concern that is at least 51 percent
owned or controlled by socially and economically disadvantaged individuals, an
economically disadvantaged Indian tribe, or an economically disadvantaged Native
Hawaiian organization. 15 U.S.C. § 637(a)(4). Socially disadvantaged individuals are
those who have been subjected to racial or ethnic prejudice or cultural bias because of
their identity as a member of a group without regard to their individual qualities. 15 U.S.C.
§ 637(a)(5). Economically disadvantaged individuals are those socially disadvantaged
individuals whose ability to compete in the free enterprise system has been impaired due
to diminished capital and credit opportunities as compared to others in the same business
area who are not socially disadvantaged. 15 U.S.C. § 637(a)(6). ARPA also created the
Restaurant Revitalization Fund to support eligible entities suffering revenue losses from
the COVID-19 pandemic. ARPA, § 5003. Court rulings found that SBA’s use of race-
based and sex-based preferences in the Restaurant Revitalization Fund award assistance
was unconstitutional. See, for example, Vitolo v. Guzman, 999 F, 3d 353 (6th Cir. 2021).
GAO, Restaurant Revitalization Fund: Opportunities Exist to Improve Oversight,
GAO-22-105442 (Washington, D.C.: July 14, 2022).
9SBA considered nearly all small businesses were likely COVID-19 affected businesses.
10Throughout this report, we define microbusinesses as businesses that reported having
between zero and nine employees. According to SBA staff, businesses that reported
being currently in business and having zero or one employee were considered sole
proprietors.
Page 4 GAO-25-107067 Small Business Pilot Program
• Veterans and military entrepreneurs (including spouses) 11
• Tribal communities 12
• Lesbian, gay, bisexual, transgender, or queer (LGBTQ)
entrepreneurs 13
To better reach these small business owners, SBA aimed to partner with
new and existing partner organizations that had established relationships
and experience working in targeted communities, according to the notice
of funding opportunity.
Navigator Program The American Rescue Plan Act of 2021 authorized SBA to award $100
Funding and Structure million for Navigator Program activities. 14 SBA awarded $99.9 million
across 51 grants in three amounts for projects at different scales. SBA
funded the 51 grants as follows:
• $5 million for multi-state projects in service areas with more than
500,000 people,
• $2.5 million for state or regional projects in service areas with at least
500,000 people,
• $1 million for local or regional projects in service areas with fewer than
500,000 people.
“Hubs”, who were the grantees, included local governments, nonprofits,
community development financial institutions, higher education
institutions, and SBA resource partners. SBA required “hubs” to contract
with at least five organizations, called “spokes,” and form a “hub-and-
spoke” network. Spokes were typically smaller community organizations,
such as nonprofits, higher education institutions, and private business
service providers, such as marketing professionals, accountants, and
lawyers. The staff and representatives of these “hub-and-spoke”
networks, collectively referred to as navigators, allowed hubs and spokes
to leverage each other’s existing services and relationships—including in
11We refer to individuals who self-identified as veterans and military entrepreneurs as
military-connected entrepreneurs.
12As noted above, we refer to individuals who self-identified as American Indian or Alaska
Native to reflect the information available in the SBA data we analyzed.
13Throughout this report, we refer to LGBTQ+ individuals because SBA’s data collection
tool included information beyond the categories defined in the LGBTQ abbreviation.
14Pub. L. No. 117-2, § 5004.
Page 5 GAO-25-107067 Small Business Pilot Program
underserved communities—and refer current or prospective businesses
to the most suitable navigator for their specific needs. 15
During the program’s two-and-a-half-year period of operation, 51 hubs
worked with more than 450 spokes. 16 Hubs’ key responsibilities included
selecting and monitoring spokes, coordinating or providing business
assistance services including training and counseling, and completing
quarterly performance and financial reporting. Spokes’ key responsibilities
included conducting outreach, offering clients access to training and
counseling services provided by linguistically and culturally
knowledgeable experts, and helping collect client data.
The statute also authorized SBA to expend $75 million to develop and
implement a program that promoted Navigator Program services to
current or prospective small business owners. 17 According to SBA, the
agency used these funds for activities such as translating sections of
SBA’s website into languages other than English and conducting a
national marketing campaign for the program from April through
September 2023. 18
15We use the term “navigator” to refer to the staff and representatives of the hubs and
spokes comprising Navigator Program networks. SBA reported that Navigator Program
hubs or spokes served all 50 states and Puerto Rico.
16As of the Navigator Program’s second year, 13 SBDCs, 10 Women’s Business Centers,
one SCORE chapter, and one Veterans Business Outreach Center acted as navigators.
Of these, eight were hubs and 17 were spokes.
17Pub. L. No. 117-2, § 5004.
18U.S. Small Business Administration, Evaluation of the Community Navigator Pilot
Program: Final Evaluation Report (Washington, D.C.: May 2024), 65.
Page 6 GAO-25-107067 Small Business Pilot Program
Navigators Provided
Training and
Counseling to
Underserved Small
Business Owners,
and Noted Benefits
and Challenges
Training and Counseling Navigators reported providing approximately 1.37 million hours of training
Covered a Variety of to small business owners under the Navigator Program. 19 These trainings
Topics and Navigators had a median of 13 clients and lasted a median of 2 hours. According to
SBA data, training covered topics such as
Reached New and Smaller
Businesses • business operations and management (24 percent of training hours);
• business financing or capital access (15 percent); and
• marketing (12 percent).
Training that centered on a broad topic sometimes also covered multiple
related topics. For example, training centered on business plans
sometimes included information about marketing or disaster
preparedness. SBA data indicate that 16 percent of navigators’ training
hours included information on business startup or preplanning and 12
percent included information on creating business plans. This suggests
some trainees were new or prospective business owners.
In addition to training, navigators provided individual counseling sessions.
Specifically, we estimated that navigators provided counseling to 37,417
clients and navigators reported delivering 205,167 hours of counseling
19Navigator Program data in this report reflect data that navigators entered in SBA’s
Community Navigator Information Management System (COMNAVS) between December
1, 2021, and June 4, 2024. Some navigators who participated in the program’s extension
ended their grant-funded activities on May 31, 2024, and may have submitted their final
performance data after June 4, 2024. It is not possible to report the number of unique
clients that navigators trained. SBA did not require navigators to record detailed data on
clients who attended training sessions, such as their names or addresses, and attendees
may have attended more than one training session.
Page 7 GAO-25-107067 Small Business Pilot Program
(for an average of 5.5 hours per client). 20 Those counseling hours
generally focused on
• general business assistance (37 percent of counseling hours);
• loan, grant, or other applications (29 percent); and
• financial literacy and use of credit (5 percent).
SBA counseling data also suggest that the Navigator Program’s
counseling services helped reach clients new to SBA services. Thirty-
eight percent of counseling clients reported not receiving or applying for
SBA services in the previous 5 years. 21
SBA data also show that navigator clients tended to represent smaller
businesses. Among navigator clients who reported being currently in
business, 60 percent operated microbusinesses (i.e., up to nine
employees), with 37 percent identifying as sole proprietors. This aligns
with the observations of SBA staff, who noted that navigators primarily
served smaller businesses and sole proprietors, whereas other SBA
resource partner programs typically served comparatively larger
businesses. Navigators we spoke with said they often helped these
newer, smaller businesses with foundational issues, such as the steps for
accessing loans or grants. Representatives of four navigators we spoke
with said they helped explain loan application requirements, such as
providing financial statements showing a profit in prior years. 22
Data Suggest Navigator
Program Largely
Counseled Clients in
Underserved Groups
Characteristics of Navigator About 95 percent of the Navigator Program’s estimated 37,417
Program Counseling Clients counseling clients self-identified with at least one of the underserved
demographic groups or areas targeted by the program, according to our
20We estimated the number of unique counseling clients by identifying observations with
matching client information, such as clients’ addresses and telephone numbers. See app.
I for more detail.
21According to our analysis, 12 percent of counseling clients reported receiving or
applying for SBA services in the previous 5 years and 50 percent did not respond to this
voluntary field in the client intake form.
22We spoke with a total of 18 navigators, including nine hubs and nine spokes.
Page 8 GAO-25-107067 Small Business Pilot Program
analysis (see table 1). This included 81 percent who self-identified with a
minority group.
Table 1: Counseling Hours and Number of Clients SBA’s Community Navigator Pilot Program Reported for Clients Who Self-
Identified with Targeted Groups
Total counseling Number of clients Percentage of clients
hours provided counseled Percentage of clients missing data or
Targeted group (N=205,167) (N=37,417) counseled prefer not to say
Underserved 196,292 35,529 95% 4%
Minority 165,419 30,440 81% 1%
Woman 112,081 18,732 50% 17%
Rural 27,987 4,177 11% 5%
Military connected 12,672 2,296 6% 23%
Individual with a 12,356 2,382 6% 24%
disability
American Indian or 11,184 1,614 4% 22%
Alaska Native
Lesbian, gay, bisexual, 4,131 616 2% 75%
transgender, or queer
Microbusiness 127,686 22,349 60% 14%
Source: GAO analysis of Small Business Administration (SBA) data. | GAO-25-107067
Note: SBA did not collect data on clients with COVID-19 affected businesses because SBA
considered nearly all small businesses were likely affected. For the category of underserved clients,
we included the categories that aligned with SBA’s data on socially and economically disadvantaged
clients. Rural clients were identified using the U.S. Department of Agriculture’s Rural-Urban
Continuum Codes, consistent with SBA’s method. For microbusinesses, we analyzed employee
numbers reported by clients currently in business, applying SBA’s definition of fewer than 10
employees. Clients reporting having multiple attributes are represented in multiple targeted groups.
Page 9 GAO-25-107067 Small Business Pilot Program
A similar demographic analysis of training clients (as opposed to
counseling clients) was not possible because we could not identify
individual clients who attended training. 23 In addition, the voluntary nature
of the demographic fields resulted in significant missing data, limiting
SBA’s ability to measure services provided to certain targeted groups. 24
Comparison of Client We also conducted a comparative analysis of counseling client
Characteristics with Other SBA characteristics between the Navigator Program and three other SBA
Programs resource partner programs: the SBDC, Women’s Business Center, and
SCORE programs. Differences in the amount of demographic data these
programs collected do not allow for direct comparisons. Therefore, we
analyzed clients by zip code characteristics, which allowed for a more
indirect but still informative comparison across programs.
Our analysis showed the Navigator Program counseled a higher
percentage of clients from majority-minority, high-poverty, and low-
income areas compared to these three other SBA programs (see table
2). 25 For SBA’s three resource partner programs, the percentage of
counseling clients from these areas remained consistent across fiscal
years, both prior to and during the Navigator Program’s performance
period.
23Our analysis differed for counseling and training. For counseling, SBA required
navigators and resource partners to collect detailed information, including client
addresses. This allowed us to compare counseling clients by zip code characteristics.
However, training did not have similar data collection requirements, and some clients may
have attended multiple sessions. Therefore, we could not identify unique clients trained by
navigators or conduct an analysis comparable to that of counseling.
24For counseling clients, nearly one-quarter of clients did not disclose their disability
status, and nearly three-quarters did not provide information about their sexual orientation.
For training clients, Navigator Program training records often did not include information
on the number of clients by sexual orientation (74 percent lacking information), disability
status (62 percent), race (58 percent), and gender (38 percent). The high percent of data
missing for various demographic variables is a limitation of our analysis. See app. I for
more detail.
25We defined majority-minority zip codes as those with populations that are less than 50
percent White non-Hispanic based on 2020 Census data. The Veterans Business
Outreach Center program is not included in our analysis of SBA’s EDMIS-NG data
because the program’s data are stored in a separate database and are not comparable to
the data from other programs, according to SBA.
Page 10 GAO-25-107067 Small Business Pilot Program
Table 2: Percentages of Counseling Clients by Zip Code Characteristics for Selected SBA Programs
SBA program Fiscal years Majority- Rural High-poverty Low-income
minority
Community Navigator Pilot Program 2022–2023 53% 11% 29% 23%
Small Business Development Center 2019–2021 33 17 19 15
2022–2023 34 17 19 16
Women’s Business Center 2019–2021 46 9 22 17
2022–2023 47 10 22 18
SCORE 2019–2021 38 5 14 11
2022–2023 40 5 14 11
Source: GAO analysis of Small Business Administration (SBA) and U.S. Census Bureau data. | GAO-25-107067
Note: We characterized areas at the zip code level as: (1) majority-minority, where at least 50 percent
of the population identified as a minority in the 2020 Census; (2) rural, using the U.S. Department of
Agriculture’s Rural-Urban Continuum Codes; (3) high-poverty, where the poverty rate was at least 20
percent; and (4) low-income, where the zip code’s median household income was in the bottom 20
percent, according to 2018–2022 American Community Survey data. The estimates for high-poverty
and low-income have a margin of error for 95 percent confidence intervals no greater than ±0.3
percentage points. For all estimates, less than 10 percent of clients were missing data for all
observations. Individuals with missing data were excluded from the calculations.
In addition, the percentage of clients from rural areas was smaller for the
Navigator Program (11 percent) than that of the SBDC program (17
percent), and about the same or somewhat higher than that of the
Women’s Business Center and SCORE programs. The difference in
reaching rural clients between the SBDC and Navigator programs may be
attributed in part to the fact that, as of 2023, there were nearly twice as
many SBDCs as navigators. However, SBA staff and representatives of
navigators we spoke with described instances where the Navigator
Program facilitated outreach in rural areas, increased attendance at rural
events, and helped SBA district office staff reach tribal communities in
rural areas, some for the first time.
Several factors may have contributed to the differences in the client base
served by the Navigator Program compared to other SBA resource
partner programs. SBA staff said some potential clients were unfamiliar
with the other SBA resource partner programs or did not feel comfortable
engaging with them. For example, a representative from one hub noted
that the local SBDC (which was not in the navigator network) is on a
private college campus, which could intimidate some potential clients.
In addition, representatives from five navigators said that clients in certain
underserved communities may be hesitant to engage with state and
federal organizations or complete government paperwork. These clients
Page 11 GAO-25-107067 Small Business Pilot Program
may have preferred working with navigator spokes, who were often
already established in underserved communities, according to
representatives from one hub. For example, one hub representative said
spokes familiar with a minority community helped clients who required
translation services or were reluctant to disclose their ethnicity due to
concerns about discrimination.
Federal Costs for Selected To shed light on the comparative costs of selected SBA programs, we
SBA Programs analyzed SBA data. We developed program-level cost estimates that help
characterize the relative cost to the government of delivering training and
counseling services through the Navigator, SBDC, Women’s Business
Center, and SCORE programs. Our estimates used the total federal costs
SBA reported for each program for fiscal years 2022 and 2023 and do not
reflect the matching funds required for some programs. 26 To enhance
comparability, we adjusted the Navigator Program’s reported federal cost
by removing SBA’s estimated expense of developing the new Community
Navigator Information Management System compared to using an
existing system. 27 Then, we used SBA data to calculate the total hours of
individual counseling and client-hours of training these programs reported
providing in these fiscal years (see table 3). 28
26We obtained information on each program’s federal costs from SBA’s Congressional
Budget Justification for fiscal year 2025. SBDCs and Women’s Business Centers were
generally required to contribute matching funds from nonfederal sources, while SCORE
chapters and navigators were not. Cost sharing or matching means the portion of project
costs not paid by federal funds or contributions (unless otherwise authorized by federal
statute). 2 C.F.R. § 200.1. To account for SBA’s extension of the Navigator Program
through May 2024 and the subsequent extension of the grants’ closeout period through
August 2024, we included the program’s total costs for fiscal years 2022, 2023, and 2024
in our calculation.
27SBA’s other resource partner programs used EDMIS-NG, a preexisting information
management system that had been established before the Navigator Program. As a
result, these other resource partner programs’ total costs to the government in fiscal years
2022 and 2023 did not include the cost of establishing a new information management
system. SBA staff said the Navigator Program gave the agency an opportunity to establish
a modernized system, rather than using this existing system. In fiscal year 2024, SBA
replaced EDMIS-NG with a version of COMNAVS, the new system established for the
Navigator Program, according to SBA.
28We analyzed SBA data from COMNAVS and EDMIS-NG. In our analysis of SBA data,
we calculated client-hours of training by multiplying the total hours of training by the
number of attendees. The data included outliers. See app. I for more detail.
Page 12 GAO-25-107067 Small Business Pilot Program
Table 3: Client-Hours of Service Selected SBA Programs Reported Providing in Fiscal Years 2022 and 2023
Total hours of Percentage Total Percentage Total
individual service hours client-hours service hours service hours
SBA program counseling of counseling of training of training reported
Community Navigator
Pilot Program 205,167 13% 1,366,715 87% 1,571,882
Small Business
Development Center 1,547,189 43% 2,053,019 57% 3,600,208
Women’s Business
Center 216,061 17% 1,092,385 83% 1,308,446
SCORE 601,134 21% 2,254,569 79% 2,855,703
Source: GAO analysis of Small Business Administration (SBA) data. | GAO-25-107067
Note: For each program, we calculated hours of client services by combining the total hours of
individual counseling and client-hours of training. We calculated the total client-hours of training by
multiplying the total hours reported for each training by the number of attendees. The COMNAVS
data cover December 1, 2021, through May 31, 2024, and were current as of June 4, 2024. We
included outliers.
Our analysis also calculated the approximate cost to the government per
client-hour of service each of these four programs reported delivering.
• Navigator Program. The Navigator Program’s federal cost per client-
hour of service delivered was around $90 during its performance
period. 29 SBA staff said the Navigator Program’s focus on serving
socially and economically disadvantaged small business owners
resulted in navigators often working with harder-to-reach clients. They
said that this led to a lower volume of service. SBA staff also said
estimated costs of a new program like the Navigator Program may not
be directly comparable to those of established programs, such as the
SBDC program, because communities with SBDCs are already
familiar with their services. This may result in a higher volume of
service for some of the established programs.
Our analysis showed that navigators reported that most of their total
service hours were group training services. This approach may have
helped lower the program’s cost per client-hour of service, as trainers
could reach multiple clients per hour. In addition, navigators told us
they delivered training services both in-person and via recorded
webinars that did not require live interaction with clients. The use of
29The Navigator Program’s performance period spanned from December 1, 2021, through
November 30, 2023, with an optional extension until May 31, 2024, for hubs with
remaining funds. We used data current as of June 4, 2024, and some navigators may
have entered additional performance information through August 31, 2024.
Page 13 GAO-25-107067 Small Business Pilot Program
such webinars may also have lowered the Navigator Program’s
estimated cost per client-hour.
• SBDC. The SBDC program’s federal cost per client-hour of service
delivered was around $85 in fiscal year 2022 through fiscal year 2023.
Our analysis showed that the SBDC program reported delivering a
greater percentage of individual counseling services and served a
greater percentage of clients in rural areas compared to the other
resource partner programs (see tables 2 and 3). SBA staff said
SBDCs’ focus on these services may raise the program’s cost per
client-hour of service. This is because staff spend a comparatively
higher percentage of service hours working directly with individual
clients or traveling to rural areas. SBA staff also said SBDCs have
more staff available to counsel clients and typically serve larger
geographic areas than other resource partners. When including
matching funds contributed by SBDCs, the program’s overall
estimated per client-hour training and counseling cost would be
higher. 30
• Women’s Business Center. The Women’s Business Center
program’s federal cost per client-hour of service delivered was around
$45 in fiscal year 2022 through fiscal year 2023. Our analysis found
that, compared to the Navigator Program, the Women’s Business
Center program reported providing similar percentages of training and
service to rural clients (see tables 2 and 3). SBA staff said Women’s
Business Centers have fewer staff than SBDCs and may focus on
providing group training rather than individual counseling to increase
the number of clients they reach. SBA staff also said Women’s
Business Centers tend to serve cities or counties, where clients are
concentrated in smaller geographic areas. This may lower the
program’s cost per client-hour of service. When including matching
funds contributed by Women’s Business Centers, the program’s
overall estimated per-hour training and counseling cost would be
higher. 31
• SCORE. The SCORE program’s federal cost per client-hour of service
delivered was around $15 in fiscal year 2022 through fiscal year 2023.
Our analysis showed that the SCORE program reported providing a
slightly higher percentage of individual counseling services compared
30The organizations receiving funding to operate SBDCs were generally required to
contribute a matching amount equal to the grant amount.
31The organizations receiving funding to operate Women’s Business Centers were
required to match half of the grant amount for the first 2 years of their 5-year SBA grant
agreement, then match the full amount for the subsequent 3 years.
Page 14 GAO-25-107067 Small Business Pilot Program
to the Navigator Program. The SCORE program’s reliance on unpaid
volunteer counselors likely contributed to lowering the program’s cost
per client-hour of service.
According to SBA staff, it is difficult to develop a single program-level cost
estimate that encompasses both counseling and training services.
Varying amounts of staff time and resources are required to deliver these
services, complicating cost estimation. In addition, SBA staff said that
even when providing the same type of service, the required staff time and
resources can vary. For example, developing certain training programs
can be time-intensive, while other training may be developed and donated
by organizations such as universities, requiring minimal staff resources.
Navigators Described Navigator representatives said they experienced benefits and challenges
Benefits of the Program while implementing the program. Benefits to navigators included
enhanced capacity for outreach and individualized services, as well as
and Challenges Related to
opportunities for smaller organizations to build capacity and participate in
Delivering Services a federal grant program. Benefits to clients included new tailored
services, culturally sensitive and trusted support, services in multiple
languages, and accessible services. Challenges included establishing
effective hub-and-spoke networks, delays in disbursements of program
funds, and collecting client data.
Benefits to Navigators Representatives from hubs, spokes, and SBA staff described several
benefits for navigators, including expanded services, capacity-building for
smaller organizations, enhanced collaboration among organizations, and
enhanced outreach.
Expanded services. The Navigator Program funding expanded
navigators’ ability to provide individualized services, according to
representatives of navigators we interviewed. Six navigators we spoke
with, including four SBA resource partners, reported being able to provide
clients with more in-depth assistance, such as substantial help with
market research and business plan development. 32 Eight navigators we
spoke with said some of these expanded services continued after the
Navigator Program ended. For example, representatives from one spoke
reported that rural clients continue to access online resources the spoke
created as a navigator.
32We interviewed representatives from a nongeneralizable sample of 18 organizations that
participated in the Navigator Program, including nine hubs and nine spokes.
Page 15 GAO-25-107067 Small Business Pilot Program
Capacity-building for smaller organizations. SBA staff and navigators
we spoke with said the program’s hub-and-spoke model allowed smaller
community organizations, serving as spokes, to participate in a federal
program. For example, representatives from one hub noted that most of
their spokes were small and did not have the capacity to handle the full
range of grant management responsibilities, such as payment
management and reporting requirements. The hub-and-spoke model
addressed this by tasking the hub with overseeing these responsibilities.
Two hubs’ representatives said they also aimed to equip spokes with new
skills, such as performance data collection and graphical presentation of
accomplishments. Acquiring these skills could enhance spokes’ ability to
secure grant funding independently in the future according to the two
hubs’ representatives.
Enhanced collaboration among organizations. The Navigator Program
also increased connectivity among hubs, spokes, SBA district offices, and
SBA resource partners, according to navigator representatives we spoke
with. For example, one hub’s representative said the program
encouraged collaboration among community organizations that typically
competed for funding. Representatives from all nine hubs we contacted
said they planned to continue coordinating with their spokes, SBA district
offices, or SBA resource partners. SBA district office staff also said they
planned to continue including navigators in their communication with
other resource partners. One SBA office we spoke with said it planned to
establish a formal year-long partnership with a former hub.
Enhanced outreach. Representatives of navigators said they enhanced
their outreach by conducting in-person or tailored outreach and
leveraging existing relationships among hubs, spokes, and community
members and organizations. They said their most effective outreach
methods included canvassing businesses, holding events in locations
familiar to the targeted community, and soliciting referrals from existing
clients. In addition, representatives of one hub stated they enhanced their
outreach by hiring a business advisor who was known and trusted within
the local Hispanic community. Another hub said it conducted outreach
primarily through a Chamber of Commerce that served as a spoke,
leveraging its existing relationships with potential clients and other
spokes. A third hub reported that more than 30 local community
organizations that were not spokes, including religious organizations and
libraries, volunteered to promote the hub-and-spoke network’s services.
Page 16 GAO-25-107067 Small Business Pilot Program
Benefits to Clients Navigators and SBA staff also described several benefits for clients,
including new tailored services and culturally sensitive and trusted
support, services in multiple languages, and accessible services.
New tailored services. Five navigators reported that the program’s
resources helped them create new services tailored to their clients’
needs. For example, one spoke created a year-long program providing
military-connected business owners with dedicated counseling, training,
and networking services. Representatives of this spoke said that after
successfully piloting this model during the Navigator Program, they
secured alternative funding to continue offering the program.
Representatives of another spoke said they created webinars addressing
stress management and retirement planning after finding these topics to
be in high demand.
Culturally sensitive and trusted support. Ten of the 18 navigators we
spoke with said they leveraged their cultural knowledge or took steps to
add staff with such knowledge, helping them provide clients with culturally
sensitive support. Staff from one SBA district office said they observed
effective outreach to American Indians and Alaska Natives by a hub they
described as a trusted community advocate and partner. The hub’s
spokes focused on tribal-specific business assistance issues, which differ
from those of other communities, according to the district office staff.
Representatives of one hub told us they used funding to hire staff who
conducted in-person outreach to small business owners in a minority
community. Some owners, particularly immigrants, were hesitant to
engage with government services. By canvassing the area, staff were
able to build trust with potential clients and reach those who may be less
likely to seek resources online or respond to email outreach, according to
the hub’s representatives.
Services in multiple languages. According to our analysis, 11 percent
of counseling clients reported needing services in a language other than
English. 33 These languages most commonly included Spanish and
Chinese, and less frequently included Arabic, Korean, and Somali.
According to one SBA staff member, hubs provided culturally competent
interpreters who were essential for conveying complex ideas with the
correct terminology and context in languages other than English. This
33Among counseling clients, 68 percent reported receiving counseling services only in
English and 21 percent were missing information on the language they used.
Page 17 GAO-25-107067 Small Business Pilot Program
was particularly important for business terms that do not translate well,
such as “elevator pitch.”
Accessible services. Three navigators and SBA staff we spoke with said
the program made small business assistance services more accessible to
certain clients. For example, representatives from one hub-and-spoke
network said their spokes met with clients at nontraditional times to
accommodate small business owners with full-time jobs, such as during
the lunch hour or late evening. Representatives from one of the spokes in
this network said they offered services in trusted locations because some
clients expressed discomfort visiting the city’s downtown area. In addition,
SBA staff in one district office reported that collaborating with their
regional hub improved their understanding of how to support accessibility
for individuals with disabilities. These staff also said local SBA resource
partners applied knowledge gained from the hub and its spokes to create
more accessible spaces.
Challenges Navigators Representatives from navigators and SBA staff also described some
Described challenges in implementing the Navigator Program, including challenges
with establishing a network, delayed disbursements, data collection, and
conducting rural outreach.
Difficulty establishing a network. Representatives we interviewed from
two spokes told us their respective hubs encountered challenges in
establishing an effective navigator network. Both said they became
navigators after other spokes left the program and the hub or SBA district
office staff requested their assistance. Neither hub fostered connectivity
among the spokes in their network or provided adequate training and
communication for required reporting, according to these spoke
representatives.
Delayed disbursements. Representatives from two of the nine hubs we
interviewed reported delayed program fund disbursements from SBA after
submitting their quarterly financial reports. An SBA district office identified
two other hubs that experienced similar delays. SBA staff attributed
delays to unresolved questions about hub reports, requiring clarification
before disbursing funds. 34 SBA changed its process for requesting
34The Office of Management and Budget’s (OMB) Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards state that when using the
reimbursement method, the awarding agency must make payment within 30 calendar
days after receipt of the billing, unless the agency reasonably believes the request to be
improper. 2 C.F.R. § 200.305(b)(3).
Page 18 GAO-25-107067 Small Business Pilot Program
clarification from hubs early in the program’s performance period, but staff
said this change did not expedite the review and approval of funds.
Representatives from one hub experiencing delays stated that the hub
used its own funds to provide timely payments to spokes. The second
hub stated that in one reporting period, it experienced a delay of over 4
months. Delayed payments prevented it from delivering training at a
community college, as it could not pay the instructor. This resulted in
canceled training and damaged relationships with spokes. SBA’s
contracted May 2024 implementation evaluation of the Navigator Program
identified several similar examples of delayed disbursements contributing
to financial stress among hubs and spokes. 35
Data collection challenges. Of the 18 navigators we interviewed, 13
stated they had difficulty collecting client data, including 10 who said
SBA’s required client intake form requested potentially sensitive
information. One navigator noted the form asked for a client’s Social
Security number (or Taxpayer Identification Number), implying the
navigator would check clients’ tax records. Another navigator
encountered resistance from clients when asking for demographic
information, like gender identity or sexual orientation, which it felt was
inappropriate for the tribal communities it served.
In addition, representatives of seven navigators said the form requested
more information than they would typically collect. For example, a
representative from one hub, also an SBA resource partner, said the
Navigator Program required tracking significantly more metrics than its
own resource partner program. Further, representatives of seven of the
nine hubs we spoke with said they found it difficult to navigate the
program’s new database management system.
SBA staff said the Navigator Program’s client intake form was similar to
the form used by its other resource partner programs. 36 SBA created
guidance for hubs on the form’s data fields, including guidance indicating
that certain potentially sensitive data fields were voluntary. SBA staff also
said they provided training on using COMNAVS and gathered input from
35U.S. Small Business Administration, Evaluation of the Community Navigator Pilot
Program, 103–4.
36The form used by SBA’s other resource partner programs did not include fields for
collecting a client’s sexual orientation, Social Security number, or Taxpayer Identification
Number.
Page 19 GAO-25-107067 Small Business Pilot Program
representatives of hub organizations both during COMNAVS’
development and after its deployment.
Challenges conducting rural outreach. Representatives we interviewed
from two hubs said they faced challenges conducting outreach outside of
centralized locations, limiting their reach in rural areas. Spokes were not
always geographically dispersed to reach all rural areas within a region,
and substantial travel was needed to reach small numbers of rural clients.
Prior to awarding grants, SBA’s Office of Entrepreneurial Development
Navigator Program established an implementation plan for the Navigator Program and
Partially Aligned with identified the program’s activities, outputs, and outcomes.
Most Leading We have previously reported that a well-designed pilot program can help
Practices but No ensure agency assessments produce information needed to make
effective program and policy decisions. 37 We identified five leading
Outcome Evaluation practices to design pilot programs:
Is Planned
1. Establish well-defined, appropriate, clear, and measurable objectives.
2. Articulate a data-gathering strategy and an assessment methodology.
3. Develop a data analysis and evaluation plan to track pilot
performance and implementation.
4. Identify a means to assess lessons learned about the pilot to inform
decisions on scalability, and whether and how to integrate pilot
activities into overall efforts.
5. Ensure two-way stakeholder communication at all stages of the
program.
We found that SBA’s design of the Navigator Program aligned with one of
these leading practices and partially aligned with the other four.
Well-Defined, Appropriate, We found that SBA’s pilot program design aligned with this leading
Clear, and Measurable practice. SBA’s objective was to conduct targeted outreach and increase
Objectives use of existing SBA services among underserved current or prospective
small business owners. This objective was clear, measurable, and
consistently reflected throughout program documentation, including the
37GAO, Data Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet Goal of
Reducing Recipient Reporting Burden, GAO-16-438 (Washington, D.C.: Apr. 19, 2016).
Page 20 GAO-25-107067 Small Business Pilot Program
public website, implementation plan, and logic model. 38 The program’s
May 2021 notice of funding opportunity defined target groups of
underserved small business owners, as discussed previously. In addition,
the objective addressed one of SBA’s strategic goals on equity, related to
building an equitable entrepreneurial ecosystem.
Data Gathering Strategy and SBA’s pilot program design partially aligned with this leading practice.
Assessment Methodology SBA created a data gathering strategy to capture performance
information, but it did not develop an assessment methodology that
measured the program’s objective. 39 SBA’s data gathering strategy
involved requiring hubs to use a standard form to collect qualitative and
quantitative data on their network’s clients and services, and to submit
quarterly performance reports. 40
However, SBA’s assessment methodology did not fully measure the
program’s objective. SBA’s notice of funding opportunity identified 11
performance metrics to assess the Navigator Program’s success, but
these did not include metrics for evaluating the program’s large outreach
component. 41 SBA staff told us outreach metrics could be added if the
program were renewed in the future. Further, the Navigator Program’s
metrics included outcomes, such as revenue or employee growth, that the
agency cannot attribute to program activities and that may not be well-
suited to a short-term program like the Navigator Program.
SBA planned to summarize some performance metrics by client
characteristics, such as reporting counseling hours navigators provided to
military-connected or women small business owners. SBA staff said
38A logic model is a diagram that documents a program’s theory of change, including
expected inputs, activities, outputs, and outcomes.
39A data gathering strategy includes methods for collecting data, including the timing and
frequency of the collection, and a clear plan that details the type and source of the data
necessary to evaluate the pilot. An assessment methodology acts as a strategy for
comparing the pilot implementation and results with program objectives.
40These reports included qualitative data, such as narratives describing client success
stories, and quantitative data navigators recorded in the program’s database. At the end of
the program, SBA also required hubs to submit final reports that included (1) a summary
of their impact on underserved small business owners, with supporting data, and (2) a
description of factors that affected their performance on the program’s metrics.
41Separately, SBA said it has contracted an evaluation of its use of the $75 million
appropriation to develop a marketing campaign and conduct education and outreach
activities to increase awareness and utilization of Navigator Program services by current
or prospective small business owners.
Page 21 GAO-25-107067 Small Business Pilot Program
privacy concerns prevent mandating the collection of demographic data. 42
As a result, it was not possible for SBA to assess navigators’ reach
among some of the targeted groups.
SBA’s contracted May 2024 implementation evaluation of the Navigator
Program recommended steps that would reflect fuller alignment with this
leading practice. Specifically, the evaluation suggested the agency gather
data on the nature and intensity of its engagement with underserved
clients, such as metrics on client relationships established or referrals or
other informal resources provided. 43 However, SBA staff said that adding
metrics during the pilot was not feasible, and the evaluation was not
published until the program ended in May 2024.
Data Analysis and Evaluation We found that SBA’s pilot program design partially aligned with the
Plan leading practice of developing a data analysis and evaluation plan. 44 In
September 2024, SBA awarded a contract for a formal evaluation of
Navigator Program outcomes. The contractor had proposed an evaluation
design to assess the extent to which the program achieved its intended
outputs and outcomes. SBA representatives told us that staff from the
agency’s Office of Strategic Management and Enterprise Integrity were to
collaborate with the contractor to develop an evaluation plan.
However, in February 2025, SBA officials told us the contract had been
canceled and the outcome evaluation would not be conducted. Officials
said they canceled the contract because they believed the evaluation
42SBA reported clients served by SBA resource partners in fiscal year 2022 generally did
not volunteer demographic data. SBA staff said when designing the Navigator Program,
they hoped its clients might be more likely to provide these data since it would be
collected by navigators who were known or trusted community organizations.
43U.S. Small Business Administration, Evaluation of the Community Navigator Pilot
Program, 66.
44A data analysis plan identifies who will conduct the analysis, the timeline, and the
methods for analyzing data to evaluate the program’s implementation and performance.
Page 22 GAO-25-107067 Small Business Pilot Program
would not align with recent executive orders related to government
diversity, equity, and inclusion programs. 45
Scalability SBA’s pilot program design partially aligned with the leading practice of
determining how scalability will be assessed and the information needed
to inform decisions about scalability. Scalability refers to whether and how
a new program approach can be implemented in a broader context. The
Navigator Program’s May 2024 implementation evaluation and SBA’s
annual evaluation plan included some consideration of the scalability of
the Navigator Program. 46 The implementation evaluation included a
research question, findings, and recommendations on program practices
that could be integrated into SBA’s other resource partner programs.
Additionally, the outcome evaluation was expected to identify further
lessons to inform other programs, according to SBA’s annual evaluation
plan. SBA staff said lessons learned from the Navigator Program included
insights on program design, payment processes, managing emergency
response programs, and using a hub spoke model. The purpose of the
evaluation was to ensure that these lessons were not lost.
Because SBA had not finalized a design for the outcome evaluation
before canceling the contract, it is unclear how its methodology would
have assessed scalability. The contractor’s proposal included plans to
meet with certain stakeholders to discuss preliminary findings and
collaborate on potential recommendations. However, neither the
implementation evaluation nor the proposal clearly identified methods for
45SBA staff told us they canceled the contract as of February 10, 2025, because of
Executive Orders. Exec. Order No. 14151 (90 Fed. Reg. 8339) and Exec. Order No.
14173 (90 Fed. Reg. 8633). On February 21, 2025, a U.S. District Court in Maryland
issued a preliminary injunction prohibiting the President and other persons who are in
active concert or participation with the President from pausing or changing terms of
current contracts or obligations on the basis of certain termination provisions in Exec.
Order No. 14151 and Exec. Order No. 14173. National Assoc. of Diversity Officers in
Higher Education et al. v Trump et al., Case No. 1:25-cv-00333-ABA (D. Md). The
defendants appealed the decisions on February 24, 2025. As of March 14, 2025, the
Fourth Circuit U.S. Court of Appeals granted the government’s motion for stay of the
preliminary injunction pending appeal and the appeal remained ongoing. Case No. 25-
1189.The SBA has not made a statement on how the case would impact the agency’s
decision on the contract.
46U.S. Small Business Administration, Fiscal Year 2024 Annual Evaluation Plan
(Washington, D.C.: Mar. 2023). SBA’s Annual Evaluation Plan identifies the evaluation
questions SBA planned to complete through the next fiscal year.
Page 23 GAO-25-107067 Small Business Pilot Program
assessing scalability of lessons learned from Navigator Program practices
to SBA’s other resource partner programs.
Two-Way Stakeholder SBA’s pilot program design partially aligned with the leading practice of
Communication obtaining stakeholder input at all stages of the pilot program, including
design, implementation, and assessment. According to SBA program
staff, during implementation, they maintained regular communication with
hub representatives and SBA district office staff through quarterly
meetings. SBA directed district office staff to meet with hubs quarterly and
provide technical assistance as needed. SBA program staff also said they
described the program to SBA resource partner representatives during
the Navigator Program’s first year of performance.
For the May 2024 implementation evaluation, the third-party evaluator
contracted by SBA gathered information from some key stakeholders,
including SBA headquarters staff responsible for the program, navigators,
and clients. 47 According to SBA and the contractor’s proposal, the
methodology for the outcome evaluation was to do so as well.
However, the contractor’s proposal for the outcome evaluation did not
include a plan to gather perspectives from other stakeholders who might
have useful insights. These include (1) partner organizations in SBA’s
other resource partner programs, including those who also served as
navigators; (2) SBA district office staff who worked on the program; or (3)
other SBA units, such as the Office of Small Business Development
Centers.
These stakeholders might have provided important perspectives, such as
identifying Navigator Program practices that might be integrated into other
SBA programs. Further, SBA resource partners might have identified
potential barriers to implementing these practices in their regions.
Similarly, SBA district office staff, having overseen both navigators and
resource partners in their regions, could have compared their outreach
and service delivery approaches, and the associated benefits or
challenges. Finally, other SBA units might have identified opportunities to
coordinate services among the agency’s other resource partner
programs.
47U.S. Small Business Administration, Evaluation of the Community Navigator Pilot
Program, 74. The implementation evaluation’s methodology included interviews with five
SBA program office staff, 22 hub representatives, 23 spoke representatives, and 12
navigator clients.
Page 24 GAO-25-107067 Small Business Pilot Program
As noted earlier, the Navigator Program ended in May 2024. As of
February 2025, SBA staff said there were no plans for a similar program
or to implement the outcome evaluation. However, evaluations play a key
role in strategic planning and program management, providing insights on
program design and execution. An evaluation, while taking into account
relevant executive orders, could capture valuable lessons from the
Navigator Program, informing the design and execution of future
initiatives and congressional decision-making.
Further, incorporating a scalability assessment into the evaluation would
provide insights into applying the Navigator Program’s lessons across
other SBA resource partner programs. In addition, gathering input from a
broad array of SBA staff and partner organizations would help ensure the
evaluation reflects a wide range of stakeholder perspectives useful for
informing current and future programs.
SBA Took Steps to
Mitigate Navigator
Program Fraud Risks
but Did Not Solicit
District Staff Input on
Applicants
SBA Assessed Fraud In 2022, SBA established a Fraud Risk Management Board to lead and
Risks for the Navigator oversee the agency’s fraud risk management efforts. The Board
established a strategic plan to develop and communicate an agencywide
Program
fraud risk management strategy, including defining roles and
responsibilities and developing fraud risk management training for SBA
staff. 48 In 2024, SBA established a schedule to assess fraud risk for its
major programs every 3 years. 49
48SBA staff said the agency plans to launch mandatory fraud risk management training in
fiscal year 2025, after the training has been finalized and approved by the SBA
Administrator.
49GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015). SBA developed a fraud risk assessment schedule for
its programs based on factors such as program size, complexity of processes, and GAO
or Office of Inspector General findings. SBA staff said the agency also updated its fraud
risk assessment tool in 2024.
Page 25 GAO-25-107067 Small Business Pilot Program
The Navigator Program was among the first SBA programs to undergo a
fraud risk assessment. Using a new fraud risk assessment tool, staff
identified seven fraud risks associated with Navigator Program activities.
Staff then assessed each risk’s likelihood and impact. They also
evaluated the extent to which ongoing control activities mitigated these
risks. This information formed the Navigator Program’s fraud risk profile.
Table 4 provides examples of these risks and control activities in place to
mitigate them. 50
Table 4: Description of Fraud Risks and Control Activities SBA Identified for the Community Navigator Pilot Program’s Fraud
Risk Assessment
Fraud risk Description Examples of control activities
Falsifying Hub misrepresents the proposed project in its • Designated SBA staff, including grants management staff,
application application with the intent of profiting without conduct separate reviews of application materials.
performing the duties listed. • SBA headquarters staff review quarterly performance reports
to identify differences between a hub’s proposed project and
current activities.
Fraudulent Hub charges SBA for costs that are unrelated to • SBA headquarters staff compare activities and
charges the program and with the intent of personal gain. accomplishments in hubs’ narrative reports with costs in
financial reports.
• SBA grants management staff conduct separate reviews of
financial reports before approving payments.
Fraud by A spoke of a hub commits fraud, but the hub is • SBA headquarters staff require hubs to summarize spokes’
spoke unaware. reporting by cost category.
• SBA headquarters staff provide training and technical
assistance for hubs on completing financial reports.
Falsifying Hub submits inaccurate, duplicative, or false • SBA headquarters staff review quantitative data to identify
program data data on performance and financial compliance outliers or potential errors.
reporting to continue receiving payment while out • SBA district office staff spot-check qualitative data during
of compliance. annual site visits and quarterly check-ins.
Source: GAO analysis of Small Business Administration (SBA) data. | GAO-25-107067
50The remaining three fraud risks SBA staff identified were: (1) an SBA employee or
contractor might receive benefits from a hub in exchange for overlooking a potential
compliance issue; (2) a hub might charge the same costs to the Navigator Program and
another funding source; and (3) a hub might charge allowable costs to the Navigator
Program, but the purchased goods or services could benefit a family member or business
associate, and the expenses may not be the best value for the program.
Page 26 GAO-25-107067 Small Business Pilot Program
SBA staff said the Navigator Program’s fraud risk profile was updated by
the end of 2024. SBA staff initially determined that each of the fraud risks
associated with the Navigator Program scored low on the agency’s fraud
risk rating scale. 51 To validate the initial assessment’s low-risk ratings, a
fraud risk specialist in the program office planned to review supporting
documentation of the program’s control activities, according to staff. SBA
staff said the updated fraud risk profile will benefit from improved fraud
risk management resources, such as a standardized agency-wide list of
possible fraud risks.
SBA verified that staff followed the application review and selection
process and later identified a possible improvement to the process for
future programs. After selecting grantees, SBA’s Office of Internal
Controls reviewed a sample of grant application files to confirm that staff
had documented key control activities. The review found that all required
documentation was present in each file, including verification of applicant
eligibility, checklists confirming application completeness, and signed
notices of award.
Additionally, in the program’s second year, SBA identified a potential
need to clarify its policy related to contractor payments for similar
programs in the future. Specifically, in conversation with one hub, SBA
staff learned of two spokes that had received grant funds from the hub for
providing contracted services to the Navigator Program network’s clients
and also in support of the hub’s operations (such as providing accounting
services for the hub). 52 SBA required the hub to replace both spokes and
use grant funds to pay the new spokes for only one activity. SBA staff
said the agency plans to consider policy changes intended to help ensure
future contractors do not receive multiple payments from a single grant.
51Using the fraud risk assessment tool, SBA staff scored (1) the inherent likelihood of the
fraud scheme, (2) the inherent significance and impact, (3) the effectiveness of existing
anti-fraud control activities, (4) the residual likelihood after considering the control
activities, and (5) the residual impact after considering the control activities. The tool then
automatically calculated the residual risk score, which represents the difference between
the residual likelihood and residual impact. According to the tool, risks with a low residual
risk score on the fraud risk rating scale based on known fraud vulnerabilities and
mitigation efforts have a low probability of financial, strategic, or reputational loss to the
agency and do not require additional mitigation beyond existing control activities.
52SBA staff said they did not detect these spokes’ services in support of the hub’s
operations through their reviews of the hub’s budget or financial reports because hubs
were not required to itemize indirect costs, such as rent and other operating costs.
Page 27 GAO-25-107067 Small Business Pilot Program
Other steps SBA took aimed at mitigating fraud risk for the Navigator
Program included the following:
• Quarterly financial reports. SBA required hubs to submit quarterly
financial reports to confirm that costs were allowable. SBA staff said
their reviews of these reports identified and resolved potential
instances of fraud, such as costs related to unallowed travel
expenses.
• Quarterly performance reports. SBA staff said they reviewed hubs’
quarterly performance reports to confirm that activities aligned with
their application’s proposed project. For example, SBA district office
staff said they corroborated these reports by verifying that the
services described matched performance data in the program’s
database.
• Hub training. SBA staff trained hubs on their responsibilities for
financial oversight of their spokes. 53 For example, SBA provided hubs
with a financial reporting workbook for spokes and guidance on
fundamental cost principles, such as how to assess allowability and
ensure adequate documentation of costs.
• Communication and site visits. SBA district office staff
communicated with and monitored hubs through quarterly check-ins
and annual site visits, according to SBA staff. During these site visits,
staff gathered information on hubs’ data management systems,
interactions with spokes, and best practices and lessons learned.
District office staff were also directed to conduct site visits with
selected spokes to provide direct oversight support for the largest-
scale networks.
SBA’s Assessment of Hub
Applicants Did Not
Incorporate Input from
Local Staff
Navigator Program Grant The stages of SBA’s process to select grantees for the Navigator
Application Process Program included a merit review of eligible applications for organizations
to be hubs and a risk assessment of potential grantees (see fig. 1). The
program’s notice of funding opportunity outlined criteria for SBA’s merit
53SBA staff said the agency did not have a formal relationship with spokes. Hubs selected
and contracted with spokes to establish their networks and were responsible for
confirming spokes’ eligibility to receive federal funding and overseeing spokes throughout
the program’s performance period.
Page 28 GAO-25-107067 Small Business Pilot Program
review, which included applicants’ capacity to execute the proposed
project and the reasonableness of their goals. After verifying eligibility,
staff evaluated and scored each application based on the information it
provided. According to SBA, district office staff participated in these
reviews by scoring applications for Navigator Program hub applicants
outside their own region. 54
Next, a panel of SBA staff reviewed the highest scoring applications and
selected potential grantees. The program’s notice of funding opportunity
identified steps for SBA’s assessment of risks associated with these
potential grantees, which included reviewing applicants’ financial
management systems and past performance with federal awards.
Figure 1: SBA’s Competitive Grant Application Review Stages for Hubs in the Community Navigator Pilot Program
SBA staff said the Navigator Program sought applications from
organizations that had not previously worked with SBA. To assess these
applicants’ past performance, staff said SBA grants management staff
reviewed available records in federal databases, including the Federal
Awardee Performance and Integrity Information System and the
54According to SBA’s Standard Operating Procedure for Grants Management,
representation from a district office in this merit review step is appropriate because most
of SBA’s grants are delivered through resource partners who have worked closely with
SBA district offices. The procedures note that agency staff may not score proposed
projects for any applicant for whom the staff is responsible for approving reimbursement
requests or conducting compliance activities.
Page 29 GAO-25-107067 Small Business Pilot Program
Department of the Treasury’s Do Not Pay registry. 55 SBA also instructed
applicants to provide examples of their prior experience, including
projects with a similar scope and magnitude.
Input Not Sought from District As part of its application review process, SBA did not leverage the
Office Staff knowledge of district office staff who had potential knowledge about
applicants’ risks. SBA headquarters staff told us that the agency’s district
offices are knowledgeable about their local entrepreneurial development
networks, which could include Navigator Program hub applicants. For
example, SBA staff in applicants’ local district offices may have
information relevant to assessing applicants that have not previously
worked with the agency. These staff may also have information about
which applicants and projects are likely to provide services that best meet
their local area’s small business needs. However, the program and grants
management staff did not consult district office staff about applicants from
their local networks when assessing applications’ merit or applicants’
risks before making awards.
Such consultations could incorporate historical and contextual information
when assessing applicants, providing SBA with opportunities to
proactively identify whether applicants are appropriate for the program
and to mitigate risks, including fraud risks, for approved grantees. For
example, SBA could offer additional training or require more frequent
reporting for grantees who lack a history of performance. Applicant risks
include intentional and unintentional misrepresentations by applicants,
such as overstating their capacity to execute a proposed project or failing
to set reasonable goals in their applications.
For example, SBA staff in one district office told us they were not given an
opportunity to share information before applicants were selected and they
could have identified potential risks associated with the hub in their
region. These district office staff reported that the hub had overstated its
capacity to provide assistance and SBA documentation showed the hub
had to significantly reduce the number of spokes in its network from 19 to
four within the program’s first 6 months. Representatives from one of the
hub’s spokes told us the hub did not appear to fully understand the
spoke’s business assistance services, which led to miscommunications
with navigator clients.
55SBA staff said they accessed the Federal Awardee Performance and Integrity
Information System using OMB’s System for Award Management, and Treasury’s Do Not
Pay registry using the GrantSolutions system.
Page 30 GAO-25-107067 Small Business Pilot Program
Officials from SBA’s Office of General Counsel stated that, similar to the
Navigator Program, none of SBA’s other competitive grant programs
solicit the input of district staff at any stage in the application review
process. These officials said that limiting input from SBA district office
staff helps prevent potential bias and ensure a consistent review process.
They said that considering only information sources explicitly listed in the
notice of funding opportunity helps ensure that all applicants are
evaluated based on the same criteria. The Navigator Program’s notice of
funding opportunity did not state that SBA would incorporate information
from applicants’ local district offices. However, listing all information
sources in notices of funding opportunity is not required.
Office of Management and Budget (OMB) guidance describes federal
grant application review requirements. For merit reviews, agencies must
establish standards to evaluate applications using an objective process. 56
For risk assessments, federal agencies must establish and maintain
policies and procedures to evaluate the risks posed by applicants before
issuing awards. 57 The criteria used when assessing applicants must be
described in the notice of funding opportunity. 58 According to OMB staff,
however, incorporating feedback from agency staff who are not reviewers
would be permissible depending on the review standards set by the
agency, the stage of the review, the purpose of seeking or receiving the
input, and how the relevant assessment criteria are communicated in
notices of funding opportunity. Further, OMB staff said that for merit
reviews, agencies generally design standards to ensure the objectivity of
the review process. These include ensuring the independence of merit
reviewers and avoiding conflicts of interest.
In our prior work, we have identified examples of approaches agencies
have taken to gather insights from staff familiar with applicants while
mitigating potential bias. 59 For example, the Department of Commerce’s
56The standards should identify the number of people the agency requires to participate in
the merit review process and provide opportunities for a diverse group of participants. 2
C.F.R.§ 200.205. According to OMB staff, OMB guidance does not specifically define the
additional standards that agencies must use for merit review.
572 C.F.R.§ 200.206(b). Before issuing grants, agencies must assess risks in multiple
areas, including history of performance and ability to effectively implement requirements. 2
C.F.R.§ 200.206(b)(2). According to OMB, the risk assessment generally includes
consideration of the applicant’s record of managing previous and current federal awards.
58Notices of funding opportunities requirements are detailed in 2 C.F.R.§ 200.204.
59See GAO, American Rescue Plan Act: Implementation of Economic Development,
Environment, and Wildlife Provisions, GAO-23-105795 (Washington, D.C.: Apr. 26, 2023).
Page 31 GAO-25-107067 Small Business Pilot Program
Economic Development Administration engaged local agency staff for
historical and contextual information about applicants with whom they had
experience. This information was considered as part of the merit review,
alongside other available inputs, to assess applicants and understand
associated risks. To mitigate the risk of bias, local staff were not present
during deliberation and selection. 60 The notices of funding opportunity
issued by the Economic Development Administration to award funds
provided by the American Rescue Plan Act noted that application reviews
would consider applicants’ past performance and project feasibility.
The Environmental Protection Agency provides another example of
gathering local staff input while mitigating bias. At that agency, local staff
reviewed and evaluated applications for competitive grant programs
within their region. These local offices were directed to maintain
documentation reflecting that reviewers and selection staff did not have
any conflicts of interest related to the competition or any applicants
competing for the award. 61 Similar to the Economic Development
Administration, the notices of funding opportunity issued by the
Environmental Protection Agency to award American Rescue Plan Act
funds noted that application reviews would consider applicants’ past
performance and organizational capacity. Communicating these
assessment criteria could help ensure consistent reviews.
SBA’s Standard Operating Procedure for Grants Management requires
risk management at each stage of the award life cycle to include
identifying, analyzing, and responding to risks related to achieving the
grant agreement’s objectives. 62 In addition, among the leading practices
identified in GAO’s Fraud Risk Framework is for agencies to collaborate
with internal and external stakeholders to share information on fraud
60The Economic Development Administration required local staff to present each
applicant’s proposal, including relevant historical and contextual information, to the staff
responsible for selecting potential grantees. Then, the selection staff deliberated and
selected potential grantees.
61The Environmental Protection Agency defined conflicts of interest as a direct personal,
familial, or financial relationship or connection with any of the proposals or applications
being reviewed or any of the applicants. In addition, individuals who had other types of
relationships (e.g., professional relationships, membership in the same organization) with
the proposals or applications being reviewed or any of the applicants could not review
proposals or applications submitted in response to an announcement if that relationship
would impair or influence their objectivity or impartiality in reviewing proposals or
applications and the conflict of interest could not be mitigated, avoided, or neutralized.
62According to the policy, program offices must incorporate risk identification into award
planning and risk mitigation into monitoring plans.
Page 32 GAO-25-107067 Small Business Pilot Program
risks. 63 As noted earlier, SBA does not solicit the input of district staff at
any stage in the application review process for its other competitive grant
programs. By establishing procedures to gather information from district
office staff with knowledge of applicants for the agency’s competitive
grant programs, SBA could improve its applicant assessments and better
manage potential fraud risks, while mitigating potential bias and
inconsistency.
The Navigator Program pilot offered SBA the opportunity to partner with
Conclusions organizations serving underserved communities and enhance outreach to
those communities. The program has concluded, and SBA officials said
the agency canceled its contracted outcome evaluation in response to
recent executive orders. However, conducting an evaluation—while
taking into account relevant executive orders—remains essential.
Evaluations play a key role in strategic planning and program
management, providing insights on program design and execution. The
Navigator Program pilot was established by law, and an evaluation would
help inform Congress and SBA of its effectiveness and key lessons
learned. An evaluation could ensure that lessons learned from the
Navigator Program are not lost. Additionally, by assessing scalability and
incorporating input from a broad array of SBA staff and partner
organizations, the evaluation would inform decisions on integrating these
insights into other SBA small business assistance efforts.
As part of the Navigator Program’s application review process, SBA did
not consult district office staff who had knowledge of some applicants, a
practice also absent in other SBA programs. This may deprive SBA of
valuable insights for assessing applicant quality and mitigating fraud risk.
By developing procedures (which consider items including the stage of
the review, communicating assessment criteria, and potential bias) to
solicit feedback from district staff for competitive grant applications, SBA
would be better positioned to assess program applicants and manage
potential fraud risks as its other business assistance programs continue.
We are making two recommendations to SBA:
Recommendations for
Executive Action The Administrator of SBA should complete an outcome evaluation of the
Navigator Program. The evaluation should include an assessment of the
scalability of lessons learned from pilot activities and incorporate input
63GAO-15-593SP.
Page 33 GAO-25-107067 Small Business Pilot Program
from a broad array of SBA staff and partner organizations.
(Recommendation 1)
The Administrator of SBA should, for its competitive grant programs,
implement procedures to obtain relevant information from district office
staff with knowledge of applicants. In doing so, the SBA Administrator
should consider the stage of the review at which staff should obtain such
information, how staff should identify and address potential bias, and how
to communicate relevant assessment criteria in notices of funding
opportunities. (Recommendation 2)
We provided a draft of this report to OMB and SBA for comment. The
Agency Comments draft report recommended improvements to SBA’s contracted evaluation
and Our Evaluation of Navigator Program outcomes. During SBA’s review of the draft, SBA
officials said the agency no longer intended to conduct the contracted
evaluation, and we modified our recommendation.
SBA provided a written response, reproduced in appendix III. SBA
concurred with our recommendations. However, its proposed action may
not fully address the intent of the first recommendation, which is focused
on evaluating the program’s outcomes. SBA stated it would conduct an
evaluation to identify any waste, fraud, or abuse. Such an evaluation may
provide useful information on program design and execution. However, as
stated in our recommendation, an evaluation of the program’s outcomes
should include assessing scalability and incorporate input from a broad
array of SBA staff and partner organizations. Identifying lessons learned
from the Navigator Program through such an evaluation would inform
decisions on integrating any insights into other SBA small business
assistance efforts.
SBA also provided technical comments, which we incorporated as
appropriate. OMB did not provide a formal comment letter or technical
comments.
We are sending copies of this report to the appropriate congressional
committees, Administrator of the Small Business Administration, Director
of the Office of Management and Budget, and other interested parties. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.
Page 34 GAO-25-107067 Small Business Pilot Program
If you or your staff have any questions about this report, please contact
me at NaamaneJ@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.
Jill Naamane
Director, Financial Markets and Community Investment
Page 35 GAO-25-107067 Small Business Pilot Program
List of Requesters
The Honorable Nydia M. Velázquez
Ranking Member
Committee on Small Business
House of Representatives
The Honorable Judy Chu
House of Representatives
The Honorable Sharice L. Davids
House of Representatives
The Honorable Marie Gluesenkamp Perez
House of Representatives
The Honorable Jared F. Golden
House of Representatives
The Honorable Kweisi Mfume
House of Representatives
The Honorable Chris Pappas
House of Representatives
The Honorable Hillary J. Scholten
House of Representatives
Page 36 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
This report examines (1) how and the extent to which the Small Business
Administration’s (SBA) Community Navigator Pilot Program reached
underserved small business owners, (2) the program’s alignment with
leading practices for pilot program design, and (3) the program’s efforts to
manage fraud risk.
To describe the extent to which the program reached underserved small
business owners, we obtained data from SBA’s Community Navigator
Information Management System (COMNAVS). COMNAVS included data
on training and counseling services navigators reported providing through
June 4, 2024. We used all observations in COMNAVS, each of which
describes one training session or set of sessions, one counseling session
or other client communication. The data included outliers, which we
included in our analysis. 1
We analyzed training observations from COMNAVS, which included the
date, number of sessions, number of hours, number of clients, and
training topic. We calculated client-hours of training for a single training by
multiplying the number of training hours for that observation by the
number of individuals who attended that training. To describe training
topics, we reviewed the data fields describing the topics of Navigator
Program training sessions, identified the most frequently occurring topics,
then calculated total client-hours of training that included information
about these topics. We also summarized information in the training data’s
demographic fields, including the amount of missing data.
We also analyzed data on counseling services navigators reported
providing. These observations included (1) information about the
counseling service, such as the date, number of hours, and language
used; (2) any demographic information the client reported; (3) information
about the client’s business, such as the number of employees the client
reported; and (4) information about any loan or grant applications. Each
observation related either to a specific counseling session or other client
communication, such as an email.
1A small number of training observations in COMNAVS had high values for total training
hours and total clients trained. While the median number of training hours was 2, 1
percent of trainings were 24 or more hours of training. While the median number of
individuals who participated in a training was 13, 1 percent of trainings had 348 or more
participants. Rather than make a judgement about which values were too high to be
reasonable, we decided to include all observations in our calculations.
Page 37 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
We took a number of steps to analyze the demographic composition of
counseled clients. First, we determined which counseling observations
were for the same client. To do this, we created new versions of data
fields, including clients’ email, telephone number, and street address
where all letters were lowercase, and we removed all blank characters. 2
We also removed all non-numeric characters from telephone numbers
and changed all street addresses without numbers to “missing.” Next, to
determine which observations to associate with each unique client, we
analyzed whether the following non-missing data fields were the same for
any two of the following observations:
1. Email and telephone number
2. Email and street address line 1
3. Telephone number and street address line 1
4. Email and name-state (a concatenation of first name, last name, and
state)
5. Email and organization name-state (a concatenation of organization
name and state)
6. Telephone number and name-state
7. Telephone number and organization name-state
8. Street address line 1 and name-state
9. Street address line 1 and organization name-state
We then grouped observations based on that determination. For example,
if observations A and B matched, and observations B and C matched, we
grouped observations A, B, and C as relating to the same client.
To assign demographic attributes to each unique client, we first
determined whether each grouped set of observations had an attribute,
did not have an attribute, or was missing an attribute. We classified a
client as having an attribute if the client
• had the attribute for at least one observation, and
• had the attribute for as many non-missing observations as it did not
have the attribute.
2SBA also created data fields that combined clients’ first name, last name, and state, or
clients’ organization name and state, for use as unique identifiers. We created new
versions of these data fields using the same data-cleaning process.
Page 38 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
For example, if a client received four counseling sessions and reported
their gender for only three sessions, we classified the client as female if
they reported they were female in at least two of those three sessions.
We classified a client as missing an attribute if the client was missing
information on the attribute for all observations associated with the client.
We assigned demographic attributes to each unique counseled client
using the following categories:
• Gender. Using the gender data field, we classified a client as the
gender they reported identifying with. Clients were able to identify as
male, female, nonbinary, or could self-describe or not identify their
gender.
• Minority. Using the race and ethnicity data fields, we classified a
client as being a minority if the client reported identifying as a race
other than White or if their ethnicity was Hispanic/Latino. 3
• Military-connectedness. Using the military status data field, we
classified a client as connected to the military if they reported they
were either on activity duty, a member of a reserve component, a
service-disabled veteran, a spouse of a military member, or a veteran.
• Lesbian, gay, bisexual, transgender, or queer (LGBTQ+). We
classified a client as LGBTQ+ if they used a sexual orientation or
gender data field to identify as such. 4
• Disability status. We classified a client as an individual with a
disability if they used the disability status data field to identify as such.
• Underserved. Using the above determinations, we classified a client
as underserved if we classified the client as a woman, American
Indian or Alaska Native, minority, military-connected, LGBTQ+, or an
individual with a disability. To align with SBA’s definition of socially
and economically disadvantaged clients, we also classified clients as
underserved if, using the zip code data field, we classified the clients
as from a rural area (described in greater detail below).
3Non-White individuals included those who identified as having more than one race, those
who identified as having a race of “other,” and those whose provided information that their
ancestors came from the Middle East or North Africa.
4Counseled clients were able to self-describe their sexual orientation. If a client used this
text field to indicate that they were heterosexual and had a gender of either male or
female, we classified them as not LGBTQ+.
Page 39 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
We also summarized information on other attributes counseled clients
reported, including the following:
• Microbusiness. Using data fields on business status and employee
number, we classified a client as owning a microbusiness if they
reported both that they were currently in business and that their
business had between zero and nine employees.
• Served by SBA. Using the data field that asked clients if they had
applied for or received SBA services in the past 5 years, we
summarized the proportion of clients who reported they had been
served, who reported they had not been served, and who did not
respond.
• Language used. Using the data field that asked clients whether they
needed assistance in a language other than English, we summarized
the proportion of counseling clients who reported receiving counseling
services in only English, who reported receiving counseling services
in languages other than English, and who did not respond.
We also compared characteristics of Navigator Program clients with those
of three other SBA resource partner programs’ clients: the Small
Business Development Center (SBDC), Women’s Business Center, and
SCORE programs. We chose these three programs because they
provided services similar to the Navigator Program and used SBA’s
Entrepreneurial Development Management Information System-Next
Generation (EDMIS-NG) database to store data on their clients’
characteristics.
To compare the characteristics of zip codes for clients served by SBA’s
Navigator Program and the three other SBA programs, we obtained
client-level data from the EDMIS-NG database for fiscal year 2014
through fiscal year 2023. Observations in the EDMIS-NG database
contained a variable identifying unique clients counseled by SBDCs,
Women’s Business Centers, and SCORE chapters. 5
We assigned a single zip code to each unique client. We used the modal
zip code (the zip code with the most observations) unless no unique
modal zip code could be identified, in which case we used the zip code
associated with the most observations from the earliest date. For
example, if a client’s first two counseling sessions were in zip code 11111
5According to SBA staff, Veterans Business Outreach Centers are SBA resource partners,
but the program does not use the EDMIS-NG database system.
Page 40 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
and their next two were in zip code 22222, we assigned them zip code
11111. We then restricted the sample to include only clients with an
associated observation in either fiscal year 2022 or fiscal year 2023
(coinciding with the Navigator Program’s performance period) or fiscal
year 2019 through fiscal year 2021 (the preceding period).
Using these zip code data, we compared counseled clients’ geographic
characteristics using the following categories:
• Majority-minority. We defined majority-minority zip codes as those
with populations that are less than 50 percent White non-Hispanic
based on 2020 Census data. 6
• Rural. We defined rural zip codes as those associated with a
nonmetro county based on the county’s 2023 Rural-Urban Continuum
Code. 7 We matched clients’ zip codes, which were included in
COMNAVS and EDMIS-NG data, to the county with most of the zip
codes addresses based on the U.S. Department of Housing and
Urban Development Office of Policy Development and Research Zip
Code to Counties Crosswalk for the second quarter of 2024.
• High-poverty. We defined high-poverty zip codes as those with a
poverty rate of at least 20 percent according to the U.S. Census
Bureau’s 2018–2022 American Community Survey data.
• Low-income. We defined low-income zip codes as those with a
median household income in the bottom 20th percentile of the
distribution of median household income across zip codes according
to 2018–2022 American Community Survey data.
We used the same definitions of majority-minority, rural, high-poverty, and
low-income zip codes for the Navigator, SBDC, Women’s Business
Center, and SCORE programs.
6Zip code is not a geographic term. All data are for zip code tabulation areas, which are
the geographic area covered by a zip code. We matched zip code tabulation areas to zip
codes with the zip code tabulation area’s number. For the purposes of this report, we use
“zip code” to refer to a zip code tabulation area.
7U.S. Department of Agriculture’s Rural-Urban Continuum Codes classify U.S. counties as
metro or nonmetro based first on if the county has or is economically tied to an urban area
with at least 50,000 individuals. Metro counties are further classified by metro area
population size, while nonmetro counties are classified by urban population size and
proximity to metro counties. In our analysis, zip codes with a Rural-Urban Continuum
Code above 3 are classified as rural.
Page 41 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
Because the American Community Survey only interviews a sample of
U.S. households, each sample is only one of a large number of samples
the U.S. Census Bureau might have drawn. Because each sample could
have provided different estimates, we express our confidence in the
percentage of clients in high-poverty and low-income zip codes as a 95
percent confidence interval. This is the interval that would contain the
actual percentage of clients in high-poverty and low-income zip codes for
95 percent of the samples that could have been drawn.
We estimated confidence intervals by simulating the poverty rate and
median household income of each client’s zip code. We accomplished
this by taking a random number from a standard normal distribution,
multiplying it by the standard error (margin of error/1.645), and adding
that number to the point estimate for poverty rate or median household
income from the American Community Survey. For each simulation, we
classified the zip code as high-poverty or low-income using the same
cutoff as used for the original data. We used this technique to get 1,000
different estimates of the percentage of clients in high-poverty and low-
income zip codes. We took the margin of error for the 95 percent
confidence interval to be the difference between the 2.5 and 97.5
percentiles of the 1,000 estimates divided by 2.
To estimate the cost per client-hour of services delivered by the
Navigator, SBDC, Women’s Business Center, and SCORE programs, we
first used data fields from SBA’s COMNAVS and EDMIS-NG databases.
We calculated the total client-hours of services each program provided to
clients in fiscal years 2022 and 2023. To account for SBA’s extension of
the Navigator Program’s performance period through May 2024, we
included in our calculation the services navigators reported providing
during fiscal year 2024, using performance data that were current as of
June 4, 2024.
We defined a client-hour of service as a client receiving either 1 hour of
training or 1 hour of counseling. To calculate client-hours of training for
each training program, we multiplied the total number of clients by total
training hours. We then summed client-hours of training across training
observations in the database. To calculate hours of counseling, we
summed hours of counseling assistance across all counseling
observations in the database.
We then used SBA data on each program’s total cost in these fiscal years
from the agency’s Congressional Budget Justification and Annual
Page 42 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
Performance Report for fiscal year 2025. 8 Specifically, we identified total
program costs reported for the SBDC, Women’s Business Center, and
SCORE programs in fiscal years 2022 and 2023. To account for SBA’s
extension of the Navigator Program through May 2024 and the
subsequent extension of the grants’ closeout period through August 2024,
we included the program’s total costs for fiscal years 2022, 2023, and
2024 in our calculation. To increase comparability among these
programs, we obtained SBA’s cost estimates for various database
systems to support the Navigator Program and removed the additional
cost of establishing the COMNAVS database compared to using the
existing EDMIS-NG database. 9
We assessed the reliability of data from SBA’s COMNAVS and EDMIS-
NG databases. To do so, we reviewed information about the distribution
and percentage of missing observations for each variable, reviewed
relevant documents, and discussed the reliability of the data with SBA
staff, including data collection methods. We determined that the
COMNAVS data were sufficiently reliable for determining (1) the number
of Navigator Program clients and hours of counseling by reported
demographic groups (2) the percentage of Navigator Program clients in
different types of zip codes and (3) the number of client-hours of services
provided as part of the Navigator Program. 10 In fewer than 0.5 percent of
training and counseling observations, navigators entered service dates
that pre-date the Navigator Program’s performance period and SBA’s
deployment of COMNAVS. We understand SBA directed navigators to
use COMNAVS only to record services related to the Navigator Program.
We determined that excluding these observations had a small impact on
our calculation of total client-hours of training, client-hours of counseling,
and estimated cost per client-hour for the Navigator Program. Our
analysis included these observations. We determined that the EDMIS-NG
data were sufficiently reliable for (1) calculating the percentage of SBDC,
Women’s Business Centers, and SCORE clients from different categories
8U.S. Small Business Administration, Fiscal Year 2025 Congressional Budget Justification
and Fiscal Year 2023 Annual Performance Report (Washington, D.C.: Mar. 11, 2024).
9SBA staff said they established COMNAVS because the Navigator Program presented
an opportunity to pilot a version of its new Nexus database system. Nexus replaced
EDMIS-NG in fiscal year 2024.
10The high percent of data missing for various demographic variables is a limitation of our
analysis. For approximately 10 percent of training observations, navigators reported
holding more than one training session, and SBA data do not indicate whether all
attendees participated in each session.
Page 43 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
of zip codes and (2) calculating the number of client-hours of service
provided by SBDCs, Women’s Business Centers, and SCORE.
To assess the reliability of the 2020 Census data, we conducted
electronic data testing and reviewed relevant documents. We determined
that the data were sufficiently reliable for determining which zip codes had
majority-minority populations. To assess the reliability of the 2018–2022
5-year American Community Survey data, we conducted electronic data
testing and reviewed relevant documents. We determined the data were
sufficiently reliable to determine which zip codes had a high poverty rate
and a low median household income. To assess the reliability of the U.S.
Department of Housing and Urban Development Office of Policy
Development and Research Zip Code to Counties Crosswalk, we
reviewed documents related to the crosswalk’s contents and creation. We
concluded that the crosswalk was sufficiently reliable for mapping zip
codes to counties. To assess the reliability of the 2023 Rural-Urban
Continuum Codes, we reviewed documents related to how the 2023
Rural-Urban Continuum Codes were created and what the codes
represent. We concluded that 2023 Rural-Urban Continuum Codes were
sufficiently reliable for categorizing zip codes as being in a rural area.
To describe how organizations that participated in the Navigator Program
reached underserved small business owners, we conducted interviews
with representatives of 18 navigators. To select these navigators, we first
selected a nongeneralizable sample of nine hubs to reflect a mix of hub
grant amounts, geographic regions, and organization types (such as
nonprofits, government entities, and SBA resource partners). We then
selected nine spokes associated with these hubs, also to reflect a mix of
geographic regions and organization types. Two of these hubs and four of
these spokes were also SBA resource partners.
In our interviews with the 18 navigators, we discussed the outreach
methods navigators used, the types of services they provided, and how
they interacted with SBA and SBA resource partners. We conducted 10 of
these 18 interviews in person, mostly during three site visits in the
Southeast, West, and Midwest regions of the country. While the results of
these interviews cannot be generalized to all navigator hubs and spokes,
they provided insight into the benefits and challenges of the program.
To assess the Navigator Program’s alignment with leading practices for
pilot program design, we reviewed components identified in our previous
Page 44 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
work. 11 For our analysis, an effort was “aligned” if the underlying activities
generally reflected all or almost all of the key elements in the leading
practice. An effort was “partially aligned” if the underlying activities
reflected some of the key elements in the leading practice or if some of
the underlying activities were not fully completed. We reviewed SBA
documents including the program’s May 2021 notice of funding
opportunity, logic model, and May 2024 implementation evaluation report,
as well as SBA’s fiscal year 2024 annual evaluation plan and its
contractor’s outcome evaluation proposal. 12 To learn about SBA’s
process for designing and evaluating the program, we interviewed SBA
representatives from the Office of Entrepreneurial Development and the
Office of Strategic Management and Enterprise Integrity.
Additionally, we interviewed a selection of four SBA district offices to
obtain their perspectives on the Navigator Program, including the extent
to which navigators in their regions understood and met program
requirements. We selected these four offices to reflect a mix of
geographic regions and experiences, such as offices that supported hubs
with different grant amounts and organization types and offices that also
supported other SBA resource partners.
To assess SBA’s process for identifying and managing fraud risk for the
Navigator Program, we reviewed SBA’s fraud risk assessment of the
program, guidance for staff, and training for hub grantees. To describe
how SBA oversaw grantee compliance with program requirements and
regulations, we obtained copies of selected documentation from 10 grant
files. We reviewed selected documentation from grant files for a
judgmental selection of four of the grantees we interviewed and two
grantees whose district office we interviewed. SBA provided further
examples from four grantees we did not interview.
The documentation we reviewed included a sample of grantees’ quarterly
performance and grant closeout reports, district offices’ annual site visit
reports, and grantees’ requests for SBA approval of changes, such as to
spokes or performance goals. We also spoke to a representative from
11GAO, Data Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet Goal of
Reducing Recipient Reporting Burden, GAO-16-438 (Washington, D.C.: Apr. 19, 2016).
12A logic model is a diagram that documents a program’s theory of change, including
expected inputs, activities, outputs, and outcomes.
Page 45 GAO-25-107067 Small Business Pilot Program
Appendix I: Objectives, Scope, and
Methodology
SBA’s Office of Strategic Management and Enterprise Integrity about
SBA’s agencywide fraud risk management efforts.
Also, as part of our third objective, we reviewed SBA’s process for
selecting hub grantees for the Navigator Program. We reviewed the
agency’s Standard Operating Procedure for Grants Management, the
Navigator Program’s notice of funding opportunity, and GAO’s fraud risk
management framework. 13 We also reviewed the Office of Management
and Budget’s Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards and spoke to staff from its Office
of Federal Financial Management about competitive grant review
procedures. 14
We also reviewed our prior work on the American Rescue Plan Act that
included competitive grant review processes for the Department of
Commerce’s Economic Development Administration and the
Environmental Protection Agency. 15 We reviewed the Economic
Development Administration’s grants manual, the Environmental
Protection Agency’s policy for competition of assistance agreements, and
examples of both agencies’ notices of funding opportunity. To learn more
about SBA’s merit review process, we interviewed staff from the Office of
General Counsel. We also spoke to staff from the Economic Development
Administration to confirm our understanding of their merit review process.
We conducted this performance audit from September 2023 to March
2025 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.
13GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015).
14Office of Management and Budget, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards (codified at 2 C.F.R. pt. 200),
effective for all federal grants awarded starting in December 2014.
15GAO, American Rescue Plan Act: Implementation of Economic Development,
Environment, and Wildlife Provisions, GAO-23-105795 (Washington, D.C.: Apr. 26, 2023).
Page 46 GAO-25-107067 Small Business Pilot Program
Appendix II: Demographic Analysis of Appendix II: Demographic Analysis of
Counseling Clients in Selected SBA Programs
Counseling Clients in Selected SBA
Programs
This table summarizes demographic data voluntarily provided to the
Small Business Administration (SBA) by clients receiving counseling
services from navigators during the Community Navigator Pilot Program’s
performance period (December 2021–May 2024). It also includes data
from clients of Small Business Development Centers (SBDC), Women’s
Business Centers, and SCORE chapters for fiscal years 2022 or 2023.
For clients of SBDCs, Women’s Business Centers, and SCORE chapters
with missing demographic information, we used available records dating
back to fiscal year 2014 to complete the missing information. 1
Table 5: Demographic Attributes Reported by Counseling Clients of Selected SBA Programs in Fiscal Years 2022 or 2023
American
Individual with Military Indian or
SBA program Reported data Minority Woman a disability connected Alaska Native
Community Navigator In group 81% 50% 6% 6% 4%
Pilot Program Missing data 1% 17% 24% 23% 22%
Small Business In group 44% 51% 6% 9% 1%
Development Center Missing data 15% 4% 10% 46% 12%
Women’s Business In group 58% 80% 6% 7% 2%
Center Missing data 16% 5% 23% 49% 21%
SCORE In group 9% 16% 1% 1% 0%
Missing data 87% 75% 93% 94% 86%
Source: GAO analysis of Small Business Administration (SBA) data. | GAO-25-107067
Note: Navigator Program data reflect navigators’ entries into the SBA’s Community Navigator
Information Management System between December 1, 2021, and June 4, 2024. Some navigators
with remaining funds continued their grant-funded activities until the program ended on May 31, 2024,
and may have submitted their final performance data after June 4, 2024.
1We obtained client-level data from SBA’s Entrepreneurial Development Management
Information System-Next Generation database for fiscal year 2014 through fiscal year
2023. The database included a variable identifying unique clients counseled by SBDCs,
Women’s Business Centers, and SCORE chapters. We used any available records
associated with a unique client to fill in demographic data a client self-reported prior to
fiscal year 2022.
Page 47 GAO-25-107067 Small Business Pilot Program
Appendix III: Comments from the Small
Appendix III: Comments from the Small
Business Administration
Business Administration
Page 48 GAO-25-107067 Small Business Pilot Program
Appendix III: Comments from the Small
Business Administration
Page 49 GAO-25-107067 Small Business Pilot Program
Appendix IV: GAO Contact and Staff
Appendix IV: GAO Contact and Staff
Acknowledgments
Acknowledgments
Jill Naamane, at NaamaneJ@gao.gov
GAO Contact
In addition to the contacts named above, Andrew Pauline (Assistant
Staff Director), Elizabeth Leibinger (Analyst-in-Charge), Joshua Brownstein,
Acknowledgments Garrett Hillyer, Jill Lacey, Jeffrey Larson, Camilla Ma, Abinash Mohanty,
Christina Pineda, Jessica Sandler, Jena Sinkfield, and Jack Wang made
key contributions to this report.
Page 50 GAO-25-107067 Small Business Pilot Program
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