Restaurant Revitalization Fund: Opportunities Exist to Improve Oversight (GAO-22-105442, July 2022)

Summary

GAO's July 2022 report, GAO-22-105442, reviews the Restaurant Revitalization Fund, for which Congress appropriated $28.6 billion to SBA in March 2021. GAO reports that just over 100,000 businesses received funding, 40 percent of eligible applicants, with a median award of about $126,000. SBA prevented over 30,000 suspicious applications from receiving awards, but GAO identified systemic control weaknesses: over 4,000 recipients that applied through external vendors, which SBA considered low-risk, have been flagged for suspected fraud or ineligibility, including an alleged fraudster who received $8 million. Annual use-of-funds reports were first due in December 2021, and 32 percent were overdue as of June 2022. GAO makes seven recommendations; SBA disagreed with five, and GAO maintains all are valid.

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United States Government Accountability Office
Report to Congressional Committees

RESTAURANT
July 2022

REVITALIZATION
FUND

Opportunities Exist to
Improve Oversight

GAO-22-105442
July 2022

RESTAURANT REVITALIZATION FUND
Opportunities Exist to Improve Oversight

Highlights of GAO-22-105442, a report to
congressional committees

Why GAO Did This Study What GAO Found
In 2020 and 2021, restaurants, bars, The Restaurant Revitalization Fund was established in March 2021 to support
and other food service businesses eligible entities suffering revenue losses from the COVID-19 pandemic. The
experienced substantial revenue loss Small Business Administration (SBA) began accepting applications and awarding
and unemployment resulting from the funds in May 2021. SBA stopped accepting applications in July 2021 with the
COVID-19 pandemic. In March 2021, program oversubscribed and almost all its funds disbursed.
Congress appropriated $28.6 billion to
SBA for a Restaurant Revitalization Restaurant Revitalization Fund Award Disbursements, May 3–July 1, 2021
Fund to assist the industry.
The CARES Act includes a provision
for GAO to monitor federal efforts to
respond to the COVID-19 pandemic.
Among its objectives, this report
examines recipient characteristics,
SBA’s internal controls and fraud risk
management practices, and SBA’s
efforts to monitor recipients.
GAO reviewed SBA documentation,
analyzed SBA data on the program’s
applicants and recipients, and
interviewed SBA officials and
representatives of industry
associations.
Just over 100,000 businesses received funding (40 percent of eligible
What GAO Recommends applicants). The median award was about $126,000. Most recipients (72 percent)
GAO makes seven recommendations reported they were owned by women, veterans, or members of socially and
to SBA, including to assess pre-award economically disadvantaged groups. About 43 percent had 2019 revenue of
controls and address deficiencies, $500,000 or less.
strengthen post-award reporting, take
additional steps to identify fraudulent or
SBA emphasized pre-award controls to detect fraudulent or ineligible applications
ineligible awards, and develop and but has not assessed their effectiveness. While SBA prevented over 30,000
implement a plan to address potentially suspicious applications from receiving awards, GAO identified systemic control
fraudulent award recipients in a timely weaknesses. For example, SBA considered applications made through external
manner. SBA agreed or partially vendors to be low-risk, but over 4,000 recipients who applied through such a
agreed with two recommendations. channel have been flagged for suspected fraud or ineligibility, including an
SBA disagreed with five alleged fraudster who received $8 million. Assessing controls and addressing
recommendations, including to assess deficiencies would help SBA better ensure program integrity.
pre-award controls and implement a
SBA requires recipients to report annually on fund use, but has taken limited
plan to address fraudulent or ineligible
awards. GAO maintains that all of the steps to enforce reporting requirements and identify fraudulent or ineligible
recommendations are valid, as awards. The first reports were due in December 2021, but 32 percent were
discussed in this report. overdue as of June 2022. And SBA has not proactively used data analytics or
information from enforcement entities to identify potentially fraudulent award
recipients. SBA does not immediately investigate all potentially fraudulent
awards, and instead waits for recipients to submit final reports (which might not
be until April 30, 2023). Taking additional steps to identify and address potentially
View GAO-22-105442. For more information, fraudulent awards in a timely manner could help SBA recover funds.
contact William B. Shear at (202) 512-8678 or
ShearW@gao.gov

United States Government Accountability Office
Contents

Letter 1
Background 4
SBA Implemented RRF and Disbursed Most Funds Expeditiously 7
Smaller Disadvantaged Businesses Received Large Share of RRF
Awards 16
SBA Emphasized Pre-Award Controls to Manage Risk but Has
Not Assessed Their Effectiveness 31
SBA Has Limited Post-Award Controls for Identifying Fraudulent
or Ineligible Recipients 45
Conclusions 55
Recommendations for Executive Action 57
Agency Comments and Our Evaluation 58

Appendix I Objectives, Scope, and Methodology 66

Appendix II SBA Procedures to Verify Restaurant Revitalization Fund Applicants
Met Eligibility Requirements 70

Appendix III Comment from the Small Business Administration 71

Appendix IV GAO Contact and Staff Acknowledgments 83

Tables
Table 1: Characteristics of Restaurant Revitalization Fund (RRF)
Program 6
Table 2: SBA’s Logic Model for Restaurant Revitalization Fund 15
Table 3: Restaurant Revitalization Fund Applicants, Recipients,
and Funding, by Businesses’ 2019 Gross Receipts and
Set-Aside Goals 20
Table 4: Restaurant Revitalization Fund Applicants and
Recipients, by Business Type 21
Table 5: Restaurant Revitalization Fund Applications and
Recipients, by U.S. Territory 28
Table 6: Characteristics of Restaurant Revitalization Fund
Applicants (Unfunded and Funded) 30

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Table 7: RRF Controls That Reflect Leading Practices to Manage
Fraud Risks and Antifraud Controls in an Emergency
Environment 34
Table 8: Number and Categories of RRF Awards Selected for
Manual Review 53
Table 9: RRF Eligibility Requirements and SBA Verification
Procedures 70

Figures
Figure 1: Monthly Sales and Persons Employed in the Food
Services and Drinking Places Industry, from January
2020 to April 2021 5
Figure 2: Timeline for the Implementation of the Restaurant
Revitalization Fund (RRF) Program 8
Figure 3: Timeline for the Restaurant Revitalization Fund (RRF)
Application Process and Funding Disbursement 11
Figure 4: Restaurant Revitalization Fund Applications Received
per Day (May 3–June 10, 2021) 12
Figure 5: Restaurant Revitalization Fund Application and Funding
Approvals 13
Figure 6: Number of Restaurant Revitalization Fund Applications
by Eligibility and Funding Status 17
Figure 7: Distribution of Restaurant Revitalization Fund Awards by
Award Amount 18
Figure 8: Number of Restaurant Revitalization Fund Applicants
and Recipients, by Owner Characteristics 22
Figure 9: Median Restaurant Revitalization Fund Award Size, by
Owner Characteristics 23
Figure 10: Estimated Percentage of Eligible Businesses That
Applied to the Restaurant Revitalization Fund, by State 25
Figure 11: Percentage of Restaurant Revitalization Fund
Applications That Received Funding, by State 27
Figure 12: Median Restaurant Revitalization Fund Award Size, by
State 29
Figure 13: Restaurant Revitalization Fund (RRF) Pre-Award
Controls Process Flow 32
Figure 14: Process for Obtaining a Restaurant Revitalization Fund
(RRF) Applicant’s Tax Transcripts, by Location 43
Figure 15: Illustrative Example of a Completed Post-Award Report
for the Restaurant Revitalization Fund 46

Page ii GAO-22-105442 Restaurant Revitalization Fund
Abbreviations

ARPA American Rescue Plan Act
DOJ Department of Justice
EIDL Economic Injury Disaster Loan
IRS Internal Revenue Service
OCA Office of Capital Access
OIG Office of Inspector General
POS point of sale
PPP Paycheck Protection Program
RRF Restaurant Revitalization Fund
SBA Small Business Administration
SVOG Shuttered Venue Operators Grant

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Page iii GAO-22-105442 Restaurant Revitalization Fund
441 G St. N.W.
Washington, DC 20548

July 14, 2022

Congressional Committees

During the COVID-19 pandemic, restaurants, bars, and other food service
businesses experienced declining revenue, unemployment, and closures.
For example, their monthly sales dropped by more than half from
February 2020 to April 2020, according to Census Bureau data. 1 In
response, Congress appropriated $28.6 billion to the Small Business
Administration (SBA) for the Restaurant Revitalization Fund (RRF) to
assist eligible restaurants and other food service businesses through the
American Rescue Plan Act (ARPA) of 2021. 2 RRF awards could be used
for eligible expenses, such as payroll, business debt, maintenance, or
construction of outdoor seating.

The CARES Act includes a provision for us to monitor and oversee the
federal government’s efforts to prepare for, respond to, and recover from
the COVID-19 pandemic. In October 2021, we reported on the extent to
which RRF funds had been awarded, the geographic location of award
recipients, and award amounts. 3 This report examines (1) how SBA
implemented RRF, (2) the characteristics of RRF recipients, (3) SBA’s
steps to manage risks for RRF and the extent to which these steps align
with leading practices, and (4) SBA’s efforts to monitor recipients,
including identifying fraudulent or ineligible award recipients.

For the first objective, we reviewed SBA documentation, such as the RRF
implementation plan and program guide, and interviewed agency officials.
We analyzed SBA data on RRF applicants and recipients to determine
application volume and processing times. Additionally, we interviewed
representatives from seven industry associations representing
restaurants, other eligible businesses, and relevant stakeholders to obtain
their perspectives on SBA’s implementation of the program and members’

1The Census Bureau conducts monthly surveys to provide current estimates of sales at
retail and food services stores and inventories held by retail stores. See Census Bureau,
Monthly Retail Trade and Food Services Report, 722: Food Services and Drinking Places;
accessed January 21, 2022, at https://www.census.gov/retail/index.html.
2Pub. L. No. 117-2, § 5003(b)(2), 135 Stat. 4, 87 (codified at 15 U.S.C. § 9009c(b)(2)).

3GAO, COVID-19: Additional Actions Needed to Improve Accountability and Program
Effectiveness of Federal Response, GAO-22-105051 (Washington, D.C.: Oct. 27, 2021).

Page 1 GAO-22-105442 Restaurant Revitalization Fund
experiences with the application process. 4 We selected associations that
met at least two of the following criteria: (1) represented different sectors
of eligible businesses, (2) had testified about RRF or issued statements
or information about it, or (3) were consulted by SBA when implementing
RRF. Their views are not generalizable to other associations or all
funding recipients but offer important perspectives. Finally, we reviewed
SBA’s goals and measures for RRF and interviewed SBA officials about
performance measurement efforts.

For the second objective, we analyzed SBA’s data on RRF applicants and
recipients. From the application data, we analyzed funding requested,
demographic information, business location, business type, 2019 gross
receipts, and whether the applicant participated in other SBA pandemic
relief programs. From the recipient data, we analyzed funding requested,
demographic information, business location, and business type. We
assessed the reliability of the RRF data by reviewing related
documentation, conducting data testing to check for outliers and errors,
and interviewing agency officials. We determined these data were
sufficiently reliable to describe applicant and recipient characteristics such
as location, ownership, and revenue. We also used state-level Census
Bureau data as a proxy for businesses eligible for RRF. 5 We used these
data to estimate the percentage of eligible businesses per state that
applied for RRF. We assessed the reliability of the census data by
reviewing documentation and determined the data were sufficiently
reliable to estimate the number of eligible businesses per state.

For the third objective, we analyzed SBA documentation, including
application review plans (such as which applications received manual
review), and materials provided to application reviewers. We reviewed
SBA’s fiscal year 2021 independent financial statement audit and a report

4We interviewed or obtained written responses from representatives of the American Craft
Spirits Association, Distilled Spirits Council of America, Independent Restaurant Coalition,
National Federation of Independent Businesses, National Food Truck Association,
National Restaurant Association, and United States Hispanic Chambers of Commerce.
5Specifically, we used Statistics of U.S. Businesses 2019 data on the number of firms in
the food services and drinking place industry with less than 500 employees.

Page 2 GAO-22-105442 Restaurant Revitalization Fund
from the Pandemic Response Accountability Committee. 6 We analyzed
SBA’s applicant and recipient data to identify duplicate business locations
and tax identification numbers, and potentially ineligible businesses. We
interviewed SBA officials and the contractor that developed the RRF
application portal about controls designed to verify eligibility and address
fraud risk. Finally, we compared SBA’s policies and procedures for
managing risks against federal internal control standards for monitoring
and SBA’s goals for the RRF program. 7

For the fourth objective, we reviewed SBA documentation on its recipient
reporting requirements, improper payment testing, and procedures to
identify fraudulent or ineligible awards. We interviewed SBA officials
about these efforts. We also interviewed SBA Office of Inspector General
(OIG) officials about their coordination with SBA and referrals for potential
fraud in the RRF program. We compared SBA’s post-award monitoring
plans to federal internal control standards for control activities, GAO’s
framework for managing fraud risk, SBA standard operating procedures,
and relevant provisions in ARPA. 8 See appendix I for additional
information on our scope and methodology.

We conducted this performance audit from September 2021 to July 2022
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.

6Small Business Administration, Office of Inspector General, Independent Auditors’ Report
on SBA’s FY 2021 Financial Statements, 22-05 (Washington, D.C.: Nov. 15, 2021); and
Pandemic Response Accountability Committee, Small Business Administration Paycheck
Protection Program Phase III Fraud Controls (Washington, D.C.: Jan. 21, 2022). The
CARES Act created the Pandemic Response Accountability Committee as a committee of
the Council of the Inspectors General on Integrity and Efficiency to promote transparency
and support oversight of the federal government’s pandemic response. It comprises 21
Inspectors General.
7GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington. D.C.: Sept. 10, 2014).
8GAO, A Framework for Managing Fraud Risk in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015); GAO-14-704G, and Pub. L. No. 117-2, § 5003
(codified at 15 U.S.C. § 9009c).

Page 3 GAO-22-105442 Restaurant Revitalization Fund
Background
COVID-19’s Effect on the Restaurants, bars, caterers, food trucks, and similar businesses
U.S. Restaurant Industry experienced closures, decreased revenue, and unemployment throughout
the first year of the COVID-19 pandemic.

• Closures. About one-sixth of restaurants in the United States
temporarily or permanently closed during the pandemic. The Census
Bureau estimated that 672,602 food services and drinking place
establishments were operating in 2019. 9 The National Restaurant
Association estimated that as of December 2020, 110,000 restaurants
had temporarily or permanently closed. 10
• Decreased revenue. According to the Census Bureau, monthly sales
in the category of “food services and drinking places” dropped from
$66 billion in February 2020 to $30 billion in April 2020, and did not
return to February 2020 levels until April 2021. 11 The National
Restaurant Association also reported that such establishments
experienced a 24 percent decrease in sales in calendar year 2020
compared to 2019. 12
• Unemployment. According to the Bureau of Labor Statistics, food
services and drinking places employed 12.4 million people in
February 2020. By April 2020—a month into the pandemic—that
number dropped to 6.4 million people. 13 As of March 2021, industry
employment was still below pre-pandemic levels, with 10.2 million
people employed (see fig. 1).

9The Census Bureau’s Statistics of U.S. Businesses annual data include number of firms,
number of establishments, employment, and annual payroll for most U.S. business
establishments. See Census Bureau, 2019 SUSB Annual Data Tables by Establishment
Industry; accessed March 24, 2022, at
https://www.census.gov/data/tables/2019/econ/susb/2019-susb-annual.html.
10National Restaurant Association, State of the Restaurant Industry Report: 2021
(Washington, D.C.: Jan. 26, 2021).
11Monthly Retail Trade and Food Services Report, 722: Food Services and Drinking
Places.
12State of the Restaurant Industry Report: 2021.

13The Current Employment Statistics program produces detailed industry estimates of
nonfarm employment, hours, and earnings of workers on payrolls. Each month, the
program surveys approximately 131,000 businesses and government agencies,
representing approximately 670,000 individual worksites. See All employees, thousands,
food services and drinking places, seasonally adjusted, accessed March 24, 2022, at
https://beta.bls.gov/dataViewer/view/timeseries/CES7072200001.

Page 4 GAO-22-105442 Restaurant Revitalization Fund
Figure 1: Monthly Sales and Persons Employed in the Food Services and Drinking
Places Industry, from January 2020 to April 2021

Restaurant Revitalization In March 2021, ARPA established the RRF program to provide support to
Fund Program businesses that suffered revenue losses related to the COVID-19
pandemic. Eligible businesses were those in which patrons primarily
assembled to be served food or drink. RRF awards could be used for
expenses such as payroll, rent, utilities, and supplies. 14 For more
information, see table 1.

1415 U.S.C. § 9009c(c)(5).

Page 5 GAO-22-105442 Restaurant Revitalization Fund
Table 1: Characteristics of Restaurant Revitalization Fund (RRF) Program

Characteristic Description
Total funding $28.6 billion
Eligible entities Businesses such as restaurants, food stands, food trucks, caterers, bars, and similar places
of business that serve food or drink.
Businesses must have no more than 20 locations.
Businesses’ operating status could be open, temporarily closed, or opening soon, with
expenses incurred as of March 11, 2021.
Award size calculation In general, 2019 gross receipts (or, if the business began operations in 2019, the average
monthly gross receipts multiplied by 12) minus 2020 gross receipts. Applicants whose
businesses were not open in 2019 had to provide documentation of eligible expenses and
subtract 2020 revenue.
Applicants had to subtract any Paycheck Protection Program loans from their requested
RRF amount.a
Funding could not exceed $10 million for an applicant and affiliated businesses. Maximum
funding of $5 million per location; minimum funding amount of $1,000.
Eligible expenses Payroll (including paid sick leave); rent or mortgage payments; utilities; debt service;
construction of outdoor seating; maintenance; supplies; food and beverage (including raw
materials); covered supplier costs; and operating expenses.
Other provisions in legislation Businesses that had outstanding applications to the Shuttered Venue Operators Grant
program were ineligible.b
Businesses that receive awards and subsequently close before expending their entire award
must return unused funds.
Deadline for recipients to expend funds March 11, 2023
Source: GAO analysis of American Rescue Plan Act and Small Business Administration documentation. | GAO-22-105442
a
The program provided forgivable loans to small businesses and nonprofit organizations adversely
affected by the pandemic.
b
The program provided grants to businesses and nonprofit organizations in the performing arts and
entertainment industries adversely affected by the pandemic.

ARPA required that during the first 21 days of the program, businesses
owned and controlled by women, veterans, or socially and economically
disadvantaged small businesses as defined in the Small Business Act
receive priority in award assistance. 15 After SBA launched RRF, three
federal lawsuits were filed challenging the 21-day priority period on the
grounds that SBA’s use of race-based and sex-based preferences was

1515 U.S.C. § 9009c(c)(3). SBA defines socially disadvantaged individuals as 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, and economically
disadvantaged individuals as 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. 13 CFR §§ 124.103, 124.104.

Page 6 GAO-22-105442 Restaurant Revitalization Fund
unconstitutional. These suits led to three court rulings against SBA. 16 The
rulings did not affect the priority of veteran-owned businesses.

Starting in March 2021, SBA designed and implemented the RRF
SBA Implemented program. SBA accepted applications using online portals and awarded
RRF and Disbursed funds beginning in May 2021. By July 2021, SBA had awarded almost all
funds and stopped accepting applications with the program being
Most Funds oversubscribed. SBA plans to use program and census data to assess
Expeditiously RRF’s outcomes.

SBA Conducted SBA’s RRF implementation—which took place from March to May 2021—
Implementation Planning, included planning, collaboration with a range of stakeholders,
development of guidance, and outreach (see fig. 2). SBA delegated
Collaborated with
implementation and execution of the program to the Office of Capital
Stakeholders, Developed Access (OCA). Agency officials said they also considered assigning the
Guidance, and Held RRF program to the Office Disaster Assistance, but selected OCA
Outreach Events because the Office of Disaster Assistance was implementing the
Shuttered Venue Operators Grant (SVOG) program. 17

16Vitolo v. Guzman, 999 F.3d 353 (6th Cir. 2021); Greer’s Ranch Café v. Guzman, 540
F.Supp.3d 638 (N.D. Tex. 2021); Blessed Cajuns v. Guzman, No.4:2021cv00677 (N.D.
Tex. May 28, 2021). As a result of the litigation, SBA did not fund 2,964 priority-period
applicants approved for awards and funding went to businesses that submitted
applications before these 2,964 did. The RRF program’s funding was exhausted before
these 2,964 applications became eligible based on a first-come, first-served basis.
17Congress established SVOG in December 2020 to provide $16.25 billion in grants to
businesses and nonprofit organizations in the performing arts and entertainment industries
that were adversely affected by the pandemic.

Page 7 GAO-22-105442 Restaurant Revitalization Fund
Figure 2: Timeline for the Implementation of the Restaurant Revitalization Fund (RRF) Program

Implementation plan and collaboration. SBA completed an
implementation plan for RRF on April 8, 2021. SBA officials said the
implementation plan was created through an interagency process to
obtain feedback from internal and external stakeholders, such as staff
from other SBA offices, congressional committees, and the Office of
Management and Budget, as well as recommendations from industry
associations. The plan describes the program’s design considerations,
internal controls, reporting requirements, and contracted services.

While designing the program, SBA consulted with industry associations
and potential applicants. For example, SBA consulted with the National
Restaurant Association to discuss the restaurant industry’s experience
with other pandemic relief programs to inform RRF implementation. In
addition, SBA consulted with the Independent Restaurant Coalition on
how restaurants categorize expenses and structure ownerships. SBA
officials also said they conducted 12 focus groups to collect feedback on
the application, program guide, and other materials.

Page 8 GAO-22-105442 Restaurant Revitalization Fund
Guidance and outreach. SBA started providing guidance about RRF to
potential applicants in April 2021. Specifically, on April 19, 2021, SBA
released a sample application with details on the required information and
documentation. SBA released the RRF program guide on April 20, 2021,
which described eligibility, award amount calculations, and other program
information. 18 SBA officials said their approach to communicating policy
changes incorporated lessons learned from the Paycheck Protection
Program (PPP). 19 We previously reported that SBA did not provide timely
and complete information about PPP to applicants. 20 SBA officials said
they tried to prevent this issue with RRF by using a searchable Frequently
Asked Questions database and updating it in real time.

SBA officials also said they designed guidance and other materials to
make the program accessible to all types of restaurant owners. In addition
to English, SBA provided its RRF program guide in 17 other languages. 21
It staffed the RRF call center with English- and Spanish-speaking
contractors. SBA officials said the application guidance and materials
were designed to be easy to understand because the restaurants most
affected by pandemic-related revenue loss generally were the smallest
and sometimes owned by individuals with limited English proficiency.

To inform potential applicants about the RRF program, SBA held over 40
outreach events—such as webinars, discussions, and roundtables—with
restaurant industry associations and trade associations from April 20,
2021, to May 6, 2021, in multiple languages. Independent Restaurant
Coalition representatives we interviewed said their webinars with SBA
reached over 80,000 restaurants. Representatives from six of the seven
industry associations told us their members generally found the RRF

18SBA released an updated version of the program guide in late April 2021. Small
Business Administration, Restaurant Revitalization Funding Program: Program Guide as
of April 28, 2021 (Washington, D.C.: Apr. 28, 2021).
19The CARES Act established PPP to provide forgivable loans to small businesses and
nonprofit organizations. Qualifying businesses (in general, businesses with 500 or fewer
employees or that meet SBA’s industry-based size standard) could obtain loans equal to
2.5 months of average total monthly payments for payroll costs up to $10 million. In total,
Congress provided commitment authority of about $814 billion for PPP. It is also
administered by OCA.
20GAO, COVID-19: Opportunities to Improve Federal Response and Recovery Efforts,
GAO-20-625 (Washington, D.C.: June 25, 2020).
21Restaurant Revitalization Funding Program: Program Guide; accessed May 3, 2022, at
https://www.sba.gov/document/support-restaurant-revitalization-funding-program-guide.

Page 9 GAO-22-105442 Restaurant Revitalization Fund
program guidance and webinars helpful (one did not comment on the
issue).

SBA Used Online Portals SBA established online application portals, worked with industry partners
and Third-Party to process RRF applications, and used a risk-based approach to
determine the level of review that applications would receive. SBA worked
Information for
with a contractor to develop and operate an online application portal that
Applications and Used a included automated internal controls for application review. 22 The portal
Risk-Based Review included a two-way message capability that enabled SBA reviewers to
Process communicate with applicants and request additional information. SBA
piloted the portal to ensure its functionality and, according to SBA
officials, to optimize the user experience and RRF control framework. The
agency selected 2,600 potential applicants (randomly selected from
existing PPP participants in the restaurant industry) to test the portal from
April 25, 2021, to May 2, 2021, and provide feedback. Based on the pilot
feedback, SBA officials said they made changes to improve user
experience, revise guidance language, and update portal programming.

SBA developed partnerships with five point-of-sale (POS) vendors to
submit RRF applications or verify applicant information. POS vendors
provide inventory, sales, and payment-processing services to many
businesses in the restaurant industry. In planning documents, SBA said
that the POS vendor relationships would help them reach additional
potential applicants and reduce the burden on applicants by allowing
them to automatically complete an application with information from their
POS accounts. Two vendors allowed applicants to submit RRF
applications directly through the vendors’ platforms, using the applicants’
existing financial information, including annual revenue, to complete the
applications. 23 Three other vendors provided applicants with verified
financial reports for the SBA online portal.

SBA developed a risk-based approach to review applications. Through
this process, SBA assigned applications to a risk tier based on the dollar
amount sought, application method, and other characteristics. SBA
assembled a team of approximately 400 staff to review higher-risk
applications, while lower-risk applications were processed automatically.

22Specifically, SBA contracted with Goldschmitt-CRI, LLC, which subsequently
subcontracted with Summit Technologies, Inc. for application portal development. The
contract also included operating a call center through which applicants could receive
information about the program and application process.
23In addition to the online portal and POS vendors, applicants could apply by telephone
(through a call center).

Page 10 GAO-22-105442 Restaurant Revitalization Fund
We discuss this review process in more detail later in this report. Agency
officials said the risk-based system was based on similar risk
assessments used in the private sector and on agency experience with
PPP.

Most RRF Awards Were In late April 2021, SBA launched the RRF application portal, allowing
Processed within a Month eligible business to register. SBA started accepting applications on May
3, 2021 (see fig. 3).
and Industry Associations
Generally Viewed the
Application Process
Favorably

Figure 3: Timeline for the Restaurant Revitalization Fund (RRF) Application Process and Funding Disbursement

On the first day SBA began accepting applications, the agency received
more than 80,000 RRF applications requesting almost $34 billion (see fig.
4). SBA’s RRF portal had no reported technical issues.

Page 11 GAO-22-105442 Restaurant Revitalization Fund
Figure 4: Restaurant Revitalization Fund Applications Received per Day (May 3–June 10, 2021)

Note: Eight hundred forty-three applications were submitted during the pilot period (April 25–May 2,
2021) to test the application portal. From June 11, 2021, to July 15, 2021, 2,562 applications were
submitted.

Most applicants used SBA’s online portal to apply for RRF, instead of
POS vendors. SBA expected 70 percent of applications to be submitted
through POS vendors, according to planning documents. SBA officials
said this estimate was based on consultation with industry groups. We
found that about 6 percent of applications were submitted through POS
vendors. Agency officials said the lower number of applications submitted
through the POS vendors was the result of technical issues with the POS
portals in the first days of the application window, as well as the ease of
use of SBA’s platform. In addition, representatives from two industry
associations told us their members generally preferred completing the
application themselves through SBA’s portal rather than relying on the
automated submissions through the POS vendors.

SBA began approving applications on May 7, 2021, and disbursing funds
on May 10, 2021 (see fig. 3). By May 31, 2021, SBA had approved
88,722 applications totaling $20.4 billion—71 percent of the program’s
funding. By June 30, 2021, SBA approved $28.5 billion. The agency
processed more than 60 percent of awards within 30 days of submission
(see fig. 5). SBA officials said applications were reviewed in the order in
which they were received as determined by the date and time an

Page 12 GAO-22-105442 Restaurant Revitalization Fund
application was signed and validated by an electronic signature service.
However, as previously noted, ARPA included a 21-day priority period for
eligible entities owned and controlled by women, veterans, or socially and
economically disadvantaged small businesses as defined in the Small
Business Act. 24 SBA stopped accepting RRF applications on July 14,
2021, with the program oversubscribed. SBA officials stated they have
maintained the submitted, unapproved applications and their submission
order in the event the program receives additional funding.

Figure 5: Restaurant Revitalization Fund Application and Funding Approvals

Note: In October 2021, SBA also made five awards totaling $5.6 million. SBA officials said these
awards were made to resolve litigation.
Representatives from industry associations we interviewed generally
viewed the program favorably. Specifically, representatives from six of the
seven industry groups said their members had positive experiences with
SBA’s online portal. Representatives from four associations noted that the
RRF application was easier to complete than applications for other
COVID-19 relief programs. Representatives from four industry

24As noted previously, after RRF launched, three federal lawsuits were filed challenging
the 21-day priority period, which led to three court rulings against SBA. The rulings did not
affect the priority of veteran-owned businesses.

Page 13 GAO-22-105442 Restaurant Revitalization Fund
associations also said their members did not have issues receiving funds
once awards had been approved (three associations did not comment on
the issue).

As of June 2022, $180 million of RRF funding was unobligated, according
to USASpending.gov. 25 According to SBA officials, the unobligated
funding includes $24 million set aside for litigation, and the remainder
results from realized or anticipated recoveries. SBA data also indicate
that about $56 million came from returned awards (officials said that
awards were returned by the recipients or their financial institutions). SBA
officials said some of the recovered funds also came from awards the
Department of the Treasury administratively offset and returned to SBA. 26

SBA officials said they plan to award the remaining funds, but were taking
additional time to confirm that any new awards would comply with the
terms of legal decisions regarding the priority groups. SBA officials said
that there were specific requirements for funds returned to the agency.
Depending on the source, some funds had to be sent back to the
Department of the Treasury and could not be redistributed. In June 2022,
officials said they were working with attorneys from the Department of
Justice (DOJ) to resolve remaining litigation involving RRF and
formulating a plan on how to distribute any remaining funds.

SBA Plans to Use Census SBA is planning to assess RRF performance outcomes. SBA’s April 2021
Data to Collect Information implementation plan included a logic model describing desired outputs
and short-, intermediate-, and long-term desired outcomes (see table 2). 27
on a Few RRF
SBA officials told us their main goal for the program was to disburse
Performance Outcomes funding quickly while meeting legislative mandates. These goals are
reflected in the logic model, which includes speed of disbursement and
equitable distribution in its short-term outcomes.

25Restaurant Revitalization Fund, Small Business Administration. USASpending.gov.
Accessed on June 6, 2022, at http://www.usaspending.gov/federal_account/073-0800.
26SBA officials noted that RRF awards were not supposed to be subject to administrative
offset and they were working with the Department of the Treasury and the Department of
Justice to remedy the issue. The Department of the Treasury Offset Program collects
past-due debts (for example, child support payments) that individuals owe to state and
federal agencies.
27Outputs refer to the direct products and services delivered by a program, and outcomes
refer to the results of those products and services. GAO, Performance Measurement and
Evaluation: Definitions and Relationships, GAO-11-646SP (Washington, D.C.: May 2,
2011).

Page 14 GAO-22-105442 Restaurant Revitalization Fund
Table 2: SBA’s Logic Model for Restaurant Revitalization Fund

Long-term
Activities Outputs Short-term outcomes Intermediate outcome outcome
• Establish system to • Number of small businesses • Percent of eligible Increase in number of Increase in
collect applications assisted (funds approved and funds expended restaurants still in revenue (dollars)
and process awards disbursed) for restaurants operation at least one earned by
• Develop and issue • Average amount of award • Equitable year after funds received restaurantsa
communication on the received by each eligible distributiona (business survival)a
program for potential person or entity • Speed of
recipients • Number of completed reviews disbursement of
• Review applications and audits of funds, including relief (2-week
and make awards a description of any findings review time)
• Conduct audits of of fraud or other material
recipients and monitor noncompliance
program risk
Source: Small Business Administration (SBA). | GAO-22-105442

SBA indicated it would use census data to assess these outcomes.
a

To monitor RRF funds, SBA requires recipients to annually report on how
they have used their awards. In December 2021, SBA officials stated they
would begin to assess the program’s progress toward desired outcomes
after the first round of required recipient reporting was complete. SBA
officials said 68 percent of RRF recipients had submitted their reports as
of June 2022 (we discuss the reporting process and compliance later in
this report). For those recipients, SBA’s preliminary results showed that
about 30 percent of RRF funds had been used for payroll, 25 percent for
food and beverage purchases, and 13 percent for rent and mortgage
payments, with the remaining 32 percent split among the rest of the
categories. SBA officials said that about half of the recipients who
submitted reports said they already spent their entire award.

SBA plans to use census data to assess one of its short-term outcomes
(equitable distribution) and its intermediate- and long-term outcomes. In
April 2022, officials said they were working on an agreement with the
Census Bureau to access datasets to assess the intermediate- and long-
term outcomes. However, officials noted that as of April 2022, the
datasets of interest were only available through 2019 or 2020. Once 2021
data are available, officials said they would use taxpayer identification
numbers to match records in SBA’s RRF data with census data, which
will help SBA assess programmatic outcomes over time. SBA officials
also said they may conduct an evaluation of the RRF program at some
point in the future.

Page 15 GAO-22-105442 Restaurant Revitalization Fund
The National Restaurant Association reported that RRF awards have
been helpful to recipients. In January 2022, the association reported that
96 percent of RRF recipients responding to the association’s survey said
the award made them more likely to stay in business. Ninety-two percent
of recipient respondents said the award helped them pay expenses or
debt that had accumulated since the beginning of the pandemic. 28

About 40 percent of RRF applicants received awards, mostly of $200,000
Smaller or less. Forty-three percent of awards went to smaller-sized businesses
Disadvantaged (based on 2019 gross receipts) and about three-quarters went to
restaurants and bars. Most recipients were businesses that reported
Businesses Received being owned by women, veterans, or socially and economically
Large Share of RRF disadvantaged individuals. The percentage of applicants that received
RRF awards varied widely by state. Applicants that did not receive
Awards funding generally sought smaller amounts and submitted their
applications later than those that received funding.

28National Restaurant Association, COVID-19 Restaurant Impact Survey 1: Key Findings
– January 2022 (Washington, D.C.: January 2022). The National Restaurant Association
Research Group surveyed 4,200 restaurant operators in January 6–18, 2022. Results only
represent the views of the restaurant operators who responded to the survey.

Page 16 GAO-22-105442 Restaurant Revitalization Fund
About 40 Percent of SBA received a total of 283,741 applications, but flagged about 33,000 as
Eligible RRF Applicants likely ineligible or potentially fraudulent (see fig. 6). 29 Among the
Received Awards remaining eligible RRF applications, 100,572 received funding as of
November 2021.

Figure 6: Number of Restaurant Revitalization Fund Applications by Eligibility and Funding Status

a
The denied applications included 31,303 flagged as potentially fraudulent and 1,700 that SBA
determined were ineligible.

29SBA flagged 31,303 applications as potentially fraudulent (based on SBA’s controls
during the application review process) and determined that 1,700 applications were
ineligible. All references to “applicants” are to “eligible applicants” and exclude those SBA
flagged for potential fraud or deemed ineligible (33,003 in total). We discuss how SBA
identified potentially fraudulent or ineligible applications later in this report.

Page 17 GAO-22-105442 Restaurant Revitalization Fund
Overall, the median RRF award was $125,891. About two-thirds of all
awards were for $200,000 or less, and about 5 percent were greater than
$1 million (see fig. 7). 30 About 72 percent of awards went to applicants
who applied during the first 2 days the online application was open (May
3–4, 2021).

Figure 7: Distribution of Restaurant Revitalization Fund Awards by Award Amount

30In general, award size was calculated based on the difference between 2019 and 2020
gross receipts.

Page 18 GAO-22-105442 Restaurant Revitalization Fund
Almost Half of RRF Almost half of RRF awards went to smaller-sized business (as defined by
Awards Went to 2019 gross receipts). More specifically, about 43 percent of RRF awards
went to businesses with receipts of $500,000 or less in 2019, a group with
Businesses That Made
set aside funding (see table 3). SBA officials said the agency met the set-
$500,000 or Less in 2019 aside of $5 billion for businesses with 2019 gross receipts of $500,000 or
less, although they included businesses that were not open in 2019. 31 We
Set-Asides in the Restaurant Revitalization found that SBA awarded $4.1 billion to businesses with 2019 gross
Fund (RRF) Program
receipts of $500,000 or less, and an additional $1.1 billion to unopened
The RRF program had three set-asides to
prioritize funding to smaller businesses businesses. SBA awarded $125 million of the $500 million set aside for
(based on their pre-pandemic revenue). applicants with 2019 gross receipts of $50,000 or less (this excludes
One set-aside was included in the American unopened businesses). SBA exceeded its goal to award $4 billion to
Rescue Plan Act:
businesses with $500,000–$1.5 million in 2019 gross receipts. Overall,
(1) $5 billion for eligible businesses with
$500,000 or less in 2019 gross receipts. the median 2019 gross receipts for an RRF recipient was $523,326.
Small Business Administration (SBA) officials
said one of their goals for RRF was to make it
accessible to the smallest businesses. To do
this, SBA established two more set-asides:
(2) $500 million for eligible businesses with
$50,000 or less in 2019 gross receipts;
and
(3) $4 billion for eligible businesses with
2019 gross receipts between $500,001
and $1.5 million.
SBA based these targets on Census Bureau
data analysis and industry outreach,
according to the RRF implementation plan.
Source: GAO. | GAO-22-105442

31Businesses that were unopened as of March 11, 2021 but that had incurred eligible
expenses were eligible for RRF. In the RRF application data, these businesses report $0
in gross receipts for 2019.

Page 19 GAO-22-105442 Restaurant Revitalization Fund
Table 3: Restaurant Revitalization Fund Applicants, Recipients, and Funding, by Businesses’ 2019 Gross Receipts and Set-
Aside Goals

Number of Number of Percent of all Total funding Set-aside goal
2019 gross receipts applicants recipients awardsa ($ in billions) ($ in billions)
None (unopened business)b 35,444 5,811 6% $1.1 n/a
$500,000 or less 113,537 42,899 43% $4.1 $5
$50,000 or less 12,383 3,472 3% $0.125 $0.5
From $500,001 to $1.5 million 63,497 34,255 34% $7.9 $4
Greater than $1.5 million 38,260 17,607 18% $15.4 n/a
Source: GAO analysis of Small Business Administration data. | GAO-22-105442
a
Percentages do not total to 100 percent due to rounding.
b
Businesses that had not yet opened but had incurred eligible expenses as of March 11, 2021, were
eligible for funding. SBA officials said they included these businesses in their counts toward the set-
asides for businesses with gross receipts of $500,000 or less.

About 62 percent of RRF awards went to restaurants, followed by bars,
and businesses that were both restaurants and bars (see table 4). 32
Median award size ranged from $40,650 for food trucks to $168,259 for
restaurants and bars.

32During the RRF application, SBA asked applicants to select which business type best
applied to them. Applicants could select more than one type (such as “restaurant and bar”
or “restaurant, bar, and caterer”).

Page 20 GAO-22-105442 Restaurant Revitalization Fund
Table 4: Restaurant Revitalization Fund Applicants and Recipients, by Business Type

Number of Percent of
Type applications Number of recipients all awardsa Median award amount ($)
Restaurant 130,441 62,037 62% $137,516
Restaurant and bar 15,285 6,490 6% $168,259
Bar 10,869 4,717 5% $141,612
Food stand, food truck, or food cart 11,043 3,488 3% $40,650
Caterer 10,356 3,517 3% $125,320
Other, more than one typeb 55,963 15,071 15% $111,588
Otherc 16,781 5,252 5% $73,289
Source: GAO analysis of Small Business Administration data. | GAO-22-105442
a
Percentages do not total 100 percent due to rounding.
b
Includes all other recipients who reported more than one type of business (excluding “restaurants
and bars”).
c
Includes all other recipients who reported a single type of business: bakeries, breweries and/or
microbreweries, brewpubs, distilleries, inns, licensed alcohol producers, snack and nonalcoholic
beverage bars, taprooms, tasting rooms, wineries, and other similar places in which the primary
purpose is to assemble for food and drink.

Franchisees comprised about 8 percent of RRF applicants and 10
percent of recipients. Franchisees had a median award size of about
$115,000 (compared to $125,891 for all recipients). We previously
reported that Subway franchisees were the largest group of RRF
franchisee recipients, followed by Dunkin’ and IHOP. 33

Majority of RRF Awards About 72 percent of RRF awards went to traditionally disadvantaged
Went to Traditionally businesses—those that reported they were majority owned and controlled
by individuals who were women, veterans, or socially and economically
Disadvantaged disadvantaged (see fig. 8). 34 Such businesses constituted about 58
Businesses percent of applications. Overall, more RRF awards went to women-owned

33GAO-22-105051.

34SBA considered an applicant to be in one of these categories if the applicant was a
small business concern at least 51 percent owned by one or more individuals who were
women, veterans, or socially and economically disadvantaged and if the management and
daily business operations were controlled by one or more women, veterans, or socially
and economically disadvantaged individuals. See Restaurant Revitalization Funding
Program: Program Guide as of April 28, 2021. Applicants self-reported during application
whether their businesses met one or more of these characteristics. SBA did not verify
these self-reported classifications. We use “traditionally disadvantaged” to refer to any
business owned by women, veterans, or socially and economically disadvantaged
individuals.

Page 21 GAO-22-105442 Restaurant Revitalization Fund
businesses than to any other group, with such businesses receiving about
one-third of awards.

Figure 8: Number of Restaurant Revitalization Fund Applicants and Recipients, by
Owner Characteristics

Notes: Applicants self-reported whether they qualified as these business types. SBA did not verify
these self-reported characterizations.
a
Refers to businesses that reported belonging to more than one category (for example, owned and
controlled by women and veterans).
b
Refers to businesses that did not report being owned and controlled by women, veterans, or
members of socially and economically disadvantaged.

Overall, recipients from traditionally disadvantaged groups received
smaller awards than those not in such groups (see fig. 9). The median
award size among traditionally disadvantaged businesses ranged from

Page 22 GAO-22-105442 Restaurant Revitalization Fund
$104,387 for women-owned businesses to $135,687 for veteran-owned
businesses. The median award size for other businesses was $161,933.
In addition, while traditionally disadvantaged businesses received 72
percent of RRF awards, they received 63 percent of total award dollars
(or $17.9 billion).

Figure 9: Median Restaurant Revitalization Fund Award Size, by Owner Characteristics

Businesses owned by individuals in traditionally disadvantaged groups
might have had lower median awards because such applicants had lower
gross receipts overall: median 2019 receipts ranged from $194,671 for
business whose owners identified with at least two disadvantaged groups
to $356,513 for socially and economically disadvantaged businesses. In
contrast, businesses not owned by individuals in any traditionally
disadvantaged group had median 2019 gross receipts of $521,588. The
lower revenue also meant businesses owned by individuals in traditionally
disadvantaged groups were more likely to qualify for RRF set-asides.

Page 23 GAO-22-105442 Restaurant Revitalization Fund
Proportion of Applicants Percentages of applications and awards varied widely by state. Based on
Receiving Funding Varied census data, we estimated that about half of all potentially eligible
businesses in the United States applied for an RRF award. 35 The
by State
percentage of potentially eligible businesses that applied for funding
varied by state. For example, the percentage ranged from 31 percent in
Montana to 82 percent in Hawaii, as shown in figure 10.

35We used the Census Bureau’s 2019 Statistics of U.S. Businesses data to estimate the
number of restaurants per state potentially eligible for RRF. Specifically, we designated
“total” restaurants in each state as firms with 500 or fewer employees and a North
American Industry Classification System code definition of “Food Services and Drinking
Places” (NAICS 722) from the most recent County Business Patterns data from the
Census Bureau. While these data do not align with all eligibility criteria for RRF
recipients—such as not having more than 20 locations and receiving at least 33 percent of
their revenue from food or drink—they provide reasonable estimates for comparing eligible
business populations at the state level. The census data did not include data on U.S.
territories.

Page 24 GAO-22-105442 Restaurant Revitalization Fund
Figure 10: Estimated Percentage of Eligible Businesses That Applied to the Restaurant Revitalization Fund, by State

Note: We used the Census Bureau’s 2019 Statistics of U.S. Businesses data to estimate the number
of restaurants per state that were potentially eligible for the Restaurant Revitalization Fund, defined
as those with 500 or fewer employees and that had a North American Industry Classification System
code definition of “Food Services and Drinking Places” (NAICS 722) in the most recent census data.
While this definition does not fully align with the eligibility criteria for the Restaurant Revitalization
Fund, these data provide reasonable estimates for comparing eligible business populations at the
state level.

Page 25 GAO-22-105442 Restaurant Revitalization Fund
The percentage of applicants who received an RRF award ranged from
30 percent in Rhode Island to 51 percent in Oregon (see fig. 11).
Applicants generally applied earlier in states with higher award rates. For
example, the median application date in Rhode Island was May 11, 2021,
while in Oregon it was May 4, 2021. SBA officials noted additional factors
that could affect the percentage of applications approved by state, such
as variations among states in restaurants’ revenue, awareness of the
program, and promotion by local support organizations.

Page 26 GAO-22-105442 Restaurant Revitalization Fund
Figure 11: Percentage of Restaurant Revitalization Fund Applications That Received Funding, by State

Applicants from U.S. territories received a lower share of RRF awards
than program applicants overall (see table 5). For example, 15 percent of
applicants from Puerto Rico and 19 percent of applicants from the U.S.
Virgin Islands received awards, in contrast to 40 percent of all applicants.
SBA officials attributed the disparity to the agency’s controls for verifying

Page 27 GAO-22-105442 Restaurant Revitalization Fund
applicants’ bank accounts and tax information (we discuss these controls
in more detail later in this report). In addition, applicants from U.S.
territories generally submitted their applications about a week after the
portal opened, with a median submission date of May 12, 2021, for
Puerto Rico and May 8, 2021, for the U.S. Virgin Islands.

Table 5: Restaurant Revitalization Fund Applications and Recipients, by U.S. Territory

Percent of applications
Territory Number of applications Number of recipients receiving funding
American Samoa 6 1 17%
Commonwealth of the Northern Mariana Islands 118 12 10%
Guam 290 79 27%
Puerto Rico 2,324 339 15%
U.S. Virgin Islands 145 28 19%
Entire program 250,738a 100,572 40%
Source: GAO analysis of Small Business Administration data. | GAO-22-105442
a
Does not include applicants denied for suspected fraud or ineligibility.

Median award size by state ranged from $61,483 in South Dakota to
$181,940 in Massachusetts (see fig. 12). As previously noted, the median
award for all recipients was $125,891. In general, the median award for a
state would reflect median gross receipts reported by applicants for 2019
and 2020. Washington, D.C. had a median award size of $309,809. SBA
officials said the higher award size is likely because Washington, D.C. is
a dense area whose restaurants generally have higher revenues.
Washington, D.C.’s median award size was comparable to other large
U.S. cities, such as New York, New York ($372,926) or San Francisco,
California ($272,618). 36

36For the purposes of this analysis, a city” is defined as a “postal city” using the U.S.
Postal Service’s preferred name.

Page 28 GAO-22-105442 Restaurant Revitalization Fund
Figure 12: Median Restaurant Revitalization Fund Award Size, by State

Page 29 GAO-22-105442 Restaurant Revitalization Fund
Unfunded Applicants About 60 percent of RRF applicants (150,166) did not receive funding
Generally Sought Smaller because the program was oversubscribed. 37 These applicants generally
Awards and Applied Later sought smaller award amounts than funded applicants, were less likely to
have received PPP loans than funded applicants, and largely did not
apply on the first day of the program (see table 6). For example, the
median award request for unfunded applicants was $89,167 compared to
$125,891 for funded applicants. Also, a relatively small percentage (14
percent) of unfunded applicants applied on the first day the portal opened
compared to 58 percent of applications that were funded. To fund these
remaining applications would have required an additional $41.2 billion.

Table 6: Characteristics of Restaurant Revitalization Fund Applicants (Unfunded and Funded)

Characteristic Unfunded Funded
Number 150,166a 100,572
Total funding requested $41.2 billion $28.5 billion
Median requested award size $89,167 $125,891
Percent with no 2019 gross receipts (unopened business) 20% 6%
Percent with a Paycheck Protection Program loan 55% 89%
Percent in a traditionally disadvantaged groupb 48% 72%
Percent who applied on first day (May 3, 2021) 14% 58%
Source: GAO analysis of Small Business Administration data. | GAO-22-105442
a
Does not include applicants denied for suspected fraud or ineligibility.
b
Refers to businesses that are majority owned and controlled by individuals who are women,
veterans, or socially and economically disadvantaged.

Unfunded applicants also were more likely to meet SBA’s criteria for
manual review, such as not having a PPP loan or being an unopened
business. 38 In its internal guidance to reviewers, SBA estimated a manual
review could take 10 business days from submission, while automated
reviews were expected to take 48 hours. Since the program was
oversubscribed, applications with longer review times were less likely to
be approved before the funding was exhausted.

37This figure—150,166—does not include applicants denied for fraud or ineligibility.

38SBA required that two program staff manually review applicants who did not receive
PPP loans and those whose businesses opened after 2019 (to verify they had incurred
eligible expenses). Businesses that had not yet opened but had incurred eligible expenses
as of March 11, 2021, were eligible for RRF. In contrast, unopened businesses were
ineligible for PPP.

Page 30 GAO-22-105442 Restaurant Revitalization Fund
SBA designed the RRF application process with automated and manual
SBA Emphasized controls to screen applicants. These pre-award controls are consistent
Pre-Award Controls to with some leading practices, including a focus on fraud prevention.
However, we found weaknesses in the design and operation of pre-award
Manage Risk but Has controls, and SBA officials said they did not plan to assess whether the
Not Assessed Their controls operated as expected.
Effectiveness
RRF Reviews Designed to SBA’s pre-award controls, or reviews intended to verify an applicant’s
Verify Applicants’ Identity identity or eligibility, flagged about 12 percent of RRF applications as
potentially fraudulent (31,303 applications totaling $3 billion) or ineligible
and Eligibility Aligned with
(1,700 applications totaling $830 million) from a total of 283,741. We
Some Leading Practices discuss SBA’s application process and pre-award controls in more detail
in the following sections.

Application Review Process SBA designed the RRF application process to include a series of
Had a Series of Controls automated and manual reviews to verify applicants’ identity and eligibility
(see fig. 13). 39 SBA also developed a risk management framework for
RRF that defined if an application was high- or low-risk based on its
characteristics (such as dollar amount sought, application method, and
other characteristics). Applications deemed potentially fraudulent or
ineligible were not considered for funding. See appendix II for more
detailed information on SBA’s procedures for verifying individual eligibility
requirements.

39SBA worked with a contractor to design, build, and operate an application platform for
RRF with built in controls.

Page 31 GAO-22-105442 Restaurant Revitalization Fund
Figure 13: Restaurant Revitalization Fund (RRF) Pre-Award Controls Process Flow

Note: Applications flagged by the RRF portal or SBA payment system were reviewed by SBA staff
prior to referring the application for correction or denying it due to suspected fraud or ineligibility.

Page 32 GAO-22-105442 Restaurant Revitalization Fund
• RRF application portal. The RRF application portal included a
variety of automated controls, or steps to verify applicants’ self-
reported information against third-party information. For example,
automated controls in this system verified applicants’ bank account
information, taxpayer identification numbers and tax returns (against
IRS information), and addresses (against U.S. Postal Service address
data). Applications flagged during this process were to be manually
reviewed by SBA staff. For example, SBA officials said staff reviewed
bank account documentation when an applicant’s account could not
be verified by automated controls.
• Manual review. Two SBA staff—a reviewer and approver—were to
manually review each higher-risk application (such as those
requesting larger amounts or without PPP history). SBA assigned
approximately 400 staff from OCA and field offices to conduct these
reviews. Staff reviewed supporting documents to ensure information
was correct. 40 If staff identified incorrect information, they asked
applicants to submit a corrected application. Resubmitted applications
were subject to the same screening as initial applications. Guidance
for conducting manual reviews stated that reviewers were to focus on
confirming award amount calculations. Although the guidance stated
that the primary purpose of the reviews was not to identify potentially
fraudulent applications (because the applications were subject to
automated fraud controls prior to manual review), reviewers could flag
applications if fraud was suspected.
• SBA payment system. Prior to payment, applications were routed
through SBA’s payment system, which included additional checks.
The system compared RRF applicants with the Department of the
Treasury’s sanctions or Do Not Pay lists. 41 The system also
performed public records searches for inactive businesses, criminal
offenses, and bankruptcies. Applications flagged during this process
were to be manually reviewed.

Controls Were Consistent with SBA’s emphasis on automated, pre-award controls to prevent fraud
Some Leading Practices reflects some leading practices described in our Fraud Risk Framework
and our work on antifraud controls in an emergency environment (see

40Applicants had to provide an IRS Form 4506-T (a tax transcript request form) and
documentation of gross receipts and eligible expenses.
41The Department of the Treasury’s Do Not Pay service is an analytics tool that helps
federal agencies detect and prevent improper payments made to vendors, grantees, loan
recipients, and beneficiaries. Agencies can use the service to check multiple data sources
to make payment eligibility decisions.

Page 33 GAO-22-105442 Restaurant Revitalization Fund
table 7). 42 For example, SBA validated applicants’ information with third-
party data sources and limited applicants’ ability to modify their
information after submission.

Table 7: RRF Controls That Reflect Leading Practices to Manage Fraud Risks and Antifraud Controls in an Emergency
Environment

RRF pre-award Key leading practices for fraud risk management
activities Description and antifraud controls
RRF design and RRF application processing emphasized automated Focus on fraud prevention over detection and response
planning pre-award controls to prevent fraud. SBA staff focused to avoid a “pay and chase” model, to the extent
on reviewing higher-risk applications (determined by possible.
application characteristics).
Automated Automated controls leveraged techniques such as data Program and antifraud controls should work together to
controls matching to verify applicant identity, eligibility, and prevent fraud risk where possible.
award amounts. For example: Minimize self-reporting or verify key self-reported
• Applicant identity was verified with POS vendor, information.
IRS, and SBA data.
Authenticate identity by testing credentials against
• Self-reported eligibility requirements were verified existing information.
with IRS, SBA, and public records data.
• Award amounts and gross receipts were verified
with POS vendor data, IRS records, and PPP data.
Applications were reviewed against the Department of Conduct data matching to verify key information.
the Treasury’s Do Not Pay list.
After submission, applicant edits were limited. If an Protect data from manipulation and misuse.
applicant needed to make edits, the application was
resubmitted and then subjected to automated controls.
Manual controls Staff roles and responsibilities related to identifying and Convey fraud-specific information that is tailored to the
reporting fraud were shared in training and program and its fraud risk profile, including information
communications. on fraud risks, employees’ responsibilities, and the
effect of fraud.
Two SBA staff—a reviewer and approver—conducted Ensure payments are processed by a limited number of
manual reviews. Applications requiring manual review staff with appropriate oversight.
and documentation of such reviews was tracked Segregate duties for provision of key benefits, enforced
through RRF portal. by systems.

Legend: IRS = Internal Revenue Service; POS = point of sale; PPP = Paycheck Protection Program; RRF = Restaurant Revitalization Fund; SBA =
Small Business Administration
Source: GAO assessment of SBA documentation and interview statements. | GAO-22-105442

Note: We compared SBA’s activities against leading practices identified in our Fraud Risk Framework
(GAO-15-593SP) and in our work on internal controls and fraud risk management in emergency
response (GAO-20-625).

42GAO, A Framework for Managing Fraud Risk in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015) and GAO-20-625.

Page 34 GAO-22-105442 Restaurant Revitalization Fund
SBA officials said the emphasis on preventing fraud was based on SBA’s
experiences with PPP. We previously found that SBA had limited initial
safeguards for PPP, which increased the risk of improper payments or
misuse of funds. 43 Preventing fraud is more efficient and is less resource-
intensive than attempting to retrieve disbursed funds, which is often
referred to as the “pay and chase” model. 44 For RRF, SBA incorporated
preventative controls not initially used for PPP, such as crosschecks with
the Department of the Treasury’s Do Not Pay system. 45 We previously
reported that automated controls tend to be more reliable than manual
controls (such as document reviews) because they are less susceptible to
human error. 46

According to SBA officials, pre-award controls were revised as new
information became available during the review process. For example,
officials said they updated the controls to automatically identify applicants
using deposit accounts associated with prepaid debit cards as potentially
fraudulent (because of the lack of customer due diligence controls
associated with this banking product).

Pre-award Controls Have
Numerous Weaknesses
Systemic Control Weaknesses SBA categorized RRF applications based on certain risk factors, which it
used to determine the amount of scrutiny each application received. But
we found SBA relied on third-party controls in assigning risk tiers for
some applications, did not fully leverage data from its other COVID-19
relief programs, did not always apply risk ratings as intended,
underestimated the need for manual reviews, and did not manually review
all awards that met the criteria.

• Risk assignments for applications through POS vendors. One of
the POS vendors with which SBA worked made a technical error,
resulting in a number of potentially fraudulent awards. In its risk
management framework, SBA deemed most applications from POS
vendors to be lower-risk because the POS vendors were to employ

43GAO-20-625.

44GAO-15-593SP.

45GAO-20-625; and GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic
Enters Its Second Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021).
46GAO-15-593SP.

Page 35 GAO-22-105442 Restaurant Revitalization Fund
customer due diligence controls and verify applicants’ 2019 and 2020
sales records. 47 Because of the low-risk designation, these
applications generally did not require manual review, regardless of
amount requested. 48 However, as of November 2021, SBA data
showed that about half of the 8,129 awards that stemmed from such
applications were flagged for potential fraud or eligibility issues.
According to SBA officials, POS vendors were required to use their
revenue data to verify applicants’ 2019 and 2020 sales. However,
because of a technical error, one POS vendor did not verify these
data, increasing potential fraud risk among these applicants. SBA
officials said that when they learned of the issue, they immediately
stopped accepting applications from the vendor. SBA’s RRF data
indicates that no awards went to applications from this vendor after
May 20, 2021, but applications from this vendor were accepted until
July 2021. In addition, SBA has flagged all awards that were subject
to this technical error for its manual post-award reviews (described
later in this report).
• Use of data from other COVID-19 relief programs. SBA used
applicant and recipient data from its PPP and SVOG program to
screen RRF applicants but did not use data from its Economic Injury
Disaster Loan (EIDL) program. 49 We compared RRF and SVOG
applicant and recipient data and found that while 323 businesses
applied to both programs, no businesses received funding from
both. 50 SBA did not use the EIDL program data in its review process
because, according to SBA officials, EIDL did not require a review of

47SBA said it pursued partnerships with POS vendors because they have independent
customer due diligence processes in place and active business establishment monitoring
to provide an extra layer of protection. Each POS vendor with which SBA worked
committed to maintaining an enhanced customer due diligence program, according to the
RRF implementation plan.
48SBA officials said that applications submitted through POS vendors also went through
the same automated controls as all other applications. However, officials also noted that if
the automated controls flagged a POS application, it was referred for manual review. In
addition, according to the RRF risk management framework, applications submitted by
POS vendors without certain documentation were to be referred for manual review.
49The EIDL program provided low-interest loans to help borrowers meet obligations or pay
ordinary and necessary operating expenses. Between March 2020 and May 2021,
Congress appropriated $230 billion to the program for loans and grants (known as
advances) to assist small business affected by the pandemic.
50In general, the same business was not eligible to apply to both programs or receive
funds from both. We have ongoing work examining the SVOG program, including its
internal controls.

Page 36 GAO-22-105442 Restaurant Revitalization Fund
applicants’ tax returns and the EIDL risk-mitigation program was being
developed at the time RRF was launched. Furthermore, SBA officials
noted that they were not statutorily required to cross-check RRF
applicants with EIDL. However, our Fraud Risk Framework notes that
data matching to verify key information and eligibility is a leading
practice for managing fraud risk in federal programs. 51
• Awards with unassigned or misassigned risk tiers. In SBA’s
November 2021 RRF data, almost 40 percent of applications were
missing a risk tier assignment, including more than 16,600 that
resulted in awards. 52 According to SBA officials, applications with
missing risk tiers had not gone through IRS verification (officials said
IRS’s automated verification system could not handle the volume of
RRF applications and not all applications were verified). Officials said
that to compensate for the lack of IRS verification, these applications
should have been manually reviewed. SBA’s RRF documentation did
not describe what missing risk tiers indicate.
We also identified issues with risk tier assignments. For example,
SBA’s RRF risk-management framework deemed applications without
2019 tax returns or PPP history to be higher-risk. Thus, these
applications were supposed to be assigned to a tier that would require
manual review. However, we identified almost 2,000 awards without
PPP history assigned to a lower-risk tier. Thus, these misassigned
awards had not been manually reviewed (all had applied through POS
vendors). SBA’s data also contain a risk tier designation not described
in the risk-management framework or other documents. SBA officials
said this tier was for applications flagged by the payment system. As
of June 2022, SBA’s data and documentation did not describe these
risk tier assignment issues or the tier for payment system issues,
although it has been almost a year since most RRF awards were
disbursed.
• Greater-than-expected need for manual reviews. According to
planning documents, SBA estimated about 10 percent of applications
would require manual review. But the planning documents did not
take into account situations in which reviewers would need to review
applications flagged by automated controls. In contrast to its estimate,
SBA data indicate 71 percent of applications should have been
manually reviewed, including about 25 percent that were higher-risk.
According to SBA officials, the agency had adequate staff to respond

51GAO-15-593SP.

52According to SBA officials, original risk tier assignments can be found in additional RRF
data records that were not provided to GAO.

Page 37 GAO-22-105442 Restaurant Revitalization Fund
to the additional need for manual reviews (as previously noted, SBA
assigned around 400 staff to work on manual reviews). Furthermore,
since most applications were submitted in the first days of the
program, officials said they were able to assess the need for manual
reviews and allocate staff to meet review requirements.
• Missing manual reviews. We found SBA did not document a manual
review of all applications that met the criteria. 53 For example, none of
the unassigned applications (discussed above) have an indication of
manual review, including more than 16,600 that resulted in awards.
As noted above, SBA officials said that these applications were
missing a risk tier assignment because they had not gone through IRS
verification. Manual reviews would have helped to mitigate this
missing control. Overall, SBA’s data have no evidence of manual
review for about 17,000 awards that met the criteria (or 17 percent of
all awards). However, all awards assigned to a higher-risk tier were
manually reviewed.

DOJ has been prosecuting a recipient who allegedly received $8 million in
RRF awards by applying with stolen identities and false business
information. 54 The details of the case illustrate some of the systemic
weaknesses discussed above. The recipient submitted three applications
in May 2021 via a POS vendor and SBA did not manually review these
applications. Had the applications been reviewed, reviewers should have
identified an Oregon address for catering businesses supposedly
operating in Florida. Furthermore, per SBA’s risk-management framework
and guidance to RRF reviewers, the three applications should have been
considered higher-risk because they did not include 2019 tax documents,
and two applications did not include PPP history. Finally, the applicant
previously used false business information to apply for multiple EIDL
loans (using the same mailing address provided for the RRF applications)
in March 2021 and was rejected.

53According to SBA’s risk framework and officials’ statements, SBA staff were to manually
review RRF applications if they requested higher dollar amounts, were flagged by
automated controls, were missing a risk tier assignment, had no PPP history, or were
missing certain documentation.
54Department of Justice, Oregon Dentist Faces Federal Charges for Stealing Nearly $8
Million in COVID-Relief Program Funds (Portland, Oreg.: Dec. 15, 2021). Accessed April
5, 2022, at
https://www.justice.gov/usao-or/pr/oregon-dentist-faces-federal-charges-stealing-nearly-8-
million-covid-relief-program-funds.

Page 38 GAO-22-105442 Restaurant Revitalization Fund
Weaknesses in Execution of SBA did not fully apply additional pre-award controls to mitigate third-
Individual Controls party records limitations for applicants with some business types. In
addition, we found SBA did not fully review all available information,
allowing some applications with ineligible business types to receive
funding.

• Business types with fewer public records. SBA did not fully apply
mitigating controls to offset weaknesses in verifying eligibility for
certain businesses. SBA used a variety of methods to verify applicant
identity, such as matching business owner and restaurant names,
addresses, and taxpayer identification numbers with data from bank
accounts, IRS, and public records. But according to RRF internal
guidance, sole proprietorships, self-employed individuals, and
independent contractors applying for RRF may not have sufficient
public records for automated public records checks to verify eligibility.
About 79 percent of RRF applications identified as potentially
fraudulent from the automated controls self-identified as sole
proprietorships. Self-employed and independent contractor
businesses also were more likely to be so identified than other types.
According to SBA officials, these applications were manually reviewed
to mitigate this automated control weakness. SBA’s RRF data indicate
that 7,735 sole proprietorships, self-employed individuals, and
independent contractors received RRF awards, but only about a
quarter of these recipients were manually reviewed. The higher rates
of fraud flags and missing manual reviews or other mitigating controls
indicate potential concerns about awards to such businesses.
• Nonprofits. SBA’s data indicate that 42 RRF awards went to
nonprofits, which were ineligible for the program. We researched
these organizations and confirmed 21 actually were nonprofits. 55 In
particular, 13 of the nonprofits were veterans’ organizations, including
one that appeared to be permanently closed. 56 SBA officials stated
that the RRF application portal did not allow applicants to select
“nonprofit” as a business type; rather, this designation may have been
based on previously existing information in SBA’s payment system
(which is separate from the application system). Thus, SBA may not

55We reviewed publicly available information such as tax records, business registrations,
and affiliation with national organizations. The other reported nonprofits were confirmed as
for-profit or tribal businesses or the business type could not be confirmed with publicly
available information.
56Permanently closed businesses were ineligible for RRF. Per ARPA, RRF recipients
whose businesses permanently close before expending their entire award must return
unused funds.

Page 39 GAO-22-105442 Restaurant Revitalization Fund
have fully leveraged its existing data to verify this aspect of recipient
eligibility.
• Verification of affiliate requirements. We found SBA did not fully
verify the information that applicants reported about their affiliations.
SBA asked applicants to report any affiliates. As previously noted,
affiliated businesses were not to receive more than $10 million.
According to SBA’s RRF contractor, it was challenging to verify the
number of locations owned by an applicant because of the complex
nature of ownership structures and affiliations. SBA officials said they
generally relied on applicants’ assertions and certifications for
eligibility, as well as the additional information applicants provided.
However, we identified a group of nine affiliates that all reported the
same affiliate information and collectively received over $15 million.
These restaurants applied using the same email address. Two other
recipients also applied with this email address and received an
additional $5 million. SBA’s data show that all were manually
reviewed, but none of the review notes mention affiliate information.
SBA instructions to reviewers verifying award amounts did not include
guidance on how to review reported affiliates to ensure that groups
did not receive more than $10 million and met eligibility requirements.

SBA Does Not Plan to In April 2022, SBA officials told us they were not planning to assess
Assess Pre-award whether RRF’s pre-award controls worked as expected. In September
2021, SBA completed a fraud risk assessment for RRF that reviewed
Controls
program design and controls for potential fraud risk and concluded the
program’s controls were sufficient to mitigate fraud risk. However, this
assessment did not analyze the efficacy of pre-award controls.
Furthermore, it did not include all relevant information, such as
description and analysis of the POS vendors’ customer due diligence
controls or information on the more than 30,000 applications identified as
potentially fraudulent.

Federal internal control standards state that management should
establish and operate activities to monitor the internal control system,
evaluate the results, and remediate identified internal control deficiencies
on a timely basis. 57

A November 2021 report by SBA’s independent financial statement
auditor described weaknesses in and provided recommendations for RRF

57GAO-14-704G.

Page 40 GAO-22-105442 Restaurant Revitalization Fund
controls over the evaluation of service organizations, accounting and
monitoring, and entity-level controls. 58 The RRF-related recommendations
included that SBA perform a thorough review of awards issued and
identify potentially ineligible recipients, design and implement effective
monitoring controls to ensure recipient compliance, and develop and
implement monitoring controls to ensure an effective internal control
environment. Also, the Pandemic Response Accountability Committee
found that PPP Phase III controls applied to RRF were not sufficient to
catch known PPP fraud cases. 59 Phase III controls included verifying
applicant information (such as taxpayer identification number, legal name
of business, and business address) and crosschecking with information in
SBA’s payment system.

SBA officials told us they believed the pre-award controls aligned with
leading practices and identified over 30,000 potentially fraudulent or
ineligible applications, and thus were sufficiently robust. Officials also said
they believed the controls had worked as expected because SBA had
received few complaints about RRF through its fraud hotline.

However, without an assessment of the pre-award controls, SBA cannot
confirm the robustness of the controls and whether they operated as
expected. Such an assessment could include examining a sample of
applications from sole proprietorships (which could not be verified through
automated public records searches) and determining if the controls were
sufficient for catching potential fraudsters applying as such businesses.
The assessment also could include direct testing of internal controls. SBA
also could manually review a sample of applications denied because the
automated controls flagged them as potentially fraudulent to confirm the
automated controls operated as expected. SBA can also use the
assessment as an opportunity to document how its planned control
framework changed during implementation, such as issues with IRS
verification or adding additional risk tiers not described in the framework
documentation. In addition, SBA could use the results of its post-award

58Independent Auditors’ Report on SBA’s FY 2021 Financial Statements, 22-05. The
auditor issued a disclaimer of opinion on SBA’s consolidated financial statements for the
year ended September 30, 2021, meaning the auditor was unable to express an opinion
due to insufficient evidence. The basis for the disclaimer was that, due to inadequate
processes and controls, SBA was unable to provide adequate evidential matter in support
of a significant number of transactions and account balances related to its COVID-19 relief
programs, including RRF.
59Pandemic Response Accountability Committee, Small Business Administration
Paycheck Protection Program Phase III Fraud Controls (Washington, D.C.: Jan. 21,
2022).

Page 41 GAO-22-105442 Restaurant Revitalization Fund
manual reviews, discussed in the next section, to assess whether the
controls operated as expected.

Without comprehensively assessing the strength of pre-award controls
and taking steps to address any deficiencies, SBA increases the risk of
making awards to fraudulent or ineligible applicants with remaining
program funding. As of June 2022, there was $180 million in remaining
RRF funds, and SBA officials said they planned to make awards until all
funds were expended. In addition, documenting an assessment of the
pre-award controls could inform SBA’s control design for future
emergency programs.

Key Pre-Award Controls As previously discussed, SBA used several controls to verify RRF
May Have Disadvantaged applicants’ identities and data, such as reviewing tax returns to verify the
applicant’s identity and gross receipts (used to calculate award amounts).
Applicants from U.S.
OCA officials said that tax return verification was an important control for
Territories the RRF application process. SBA also used third-party software to verify
applicants’ bank account information. We have reported that cross-
checking with third-party data (such as tax information) can be an
effective way to verify applicant information. 60 But SBA’s design and
execution of these controls may have contributed to longer review times
for businesses in U.S. territories.

Many businesses formed in the U.S. territories do not pay federal income
taxes, and instead file with territorial tax authorities (not IRS). 61
Applications that could not be verified with IRS were referred to SBA staff
for manual review—thus, SBA would have had to manually review most
applications from businesses in U.S. territories. SBA officials stated that
manual reviews of applications from U.S. territories took more time than
manual reviews of applications from states. During the manual review,
SBA had to obtain tax information from territories’ tax authorities (see fig.
14). For most territories, SBA had to submit a tax transcript request form
to the appropriate tax authority, according to SBA officials. However, for
businesses in Puerto Rico, the Departamento de Hacienda (the
commonwealth’s tax authority) required three additional documents to
provide a tax transcript. SBA officials said reviewers directly contacted

60GAO-15-593SP.

61Congressional Research Service, Tax Policy and U.S. Territories: Overview and Issues
for Congress, R44651 (Washington, D.C.: Oct. 7, 2016). Federal taxes generally will only
be levied when a territory resident or corporation has income that can be sourced (or
connected) to the United States.

Page 42 GAO-22-105442 Restaurant Revitalization Fund
applicants to obtain these other documents, and then provided the
documents to Hacienda.

Figure 14: Process for Obtaining a Restaurant Revitalization Fund (RRF) Applicant’s Tax Transcripts, by Location

SBA officials also attributed the longer review times to the control for
verifying applicants’ bank accounts. 62 SBA used a third-party software for
this verification. However, the software was not compatible with all banks
and some applicants had to manually verify their accounts. In information
provided to RRF applicants, SBA strongly advised against manual bank

62Bank account verification was the first step in SBA’s series of pre-award controls. During
the application process, SBA asked RRF applicants to provide deposit information for the
account in which they wished to have the award deposited. SBA officials said that this was
an important control because potential fraudsters would sometimes request to have
awards deposited to prepaid credit cards.

Page 43 GAO-22-105442 Restaurant Revitalization Fund
account verification as it would significantly increase application
processing time. SBA officials said that applicants in Puerto Rico were
more likely to trigger manual bank account reviews, with 75 percent of
applications from Puerto Rico requiring manual verification.

SBA’s RRF planning documents do not describe how the control design
would affect applicants from U.S. territories. And, SBA’s guidance for staff
reviewing RRF documents does not contain information about processing
applications from U.S. territories, which may have left staff unprepared for
handling these applications. For example, we identified an instance in
which an SBA reviewer flagged an application from Puerto Rico as
ineligible because the applicant had not paid federal income tax, although
the applicant was not required to do so. As noted earlier, manual reviews
took longer than automated ones and applications requiring manual
review were less likely to be approved. Because RRF funding was quickly
exhausted by high demand, the manual review and delay in obtaining tax
information caused fewer applications from U.S. territories to receive
funding, according to SBA officials. As stated earlier, among U.S.
territories 10–27 percent of applicants received awards, compared to 40
percent program-wide.

SBA already has an example of tailoring its program procedures to
accommodate different procedures for territorial tax authorities. We
previously reported that in 2017, SBA’s Office of Disaster Assistance
instituted an alternative process for its disaster loan program that allowed
applicants from Puerto Rico to provide tax documentation later than
applicants from U.S. states. The office also provided qualified applicants
from Puerto Rico with conditional approval while obtaining and reviewing
their tax returns. 63

OCA officials said program staff worked with Office of Disaster Assistance
staff to obtain transcripts from Hacienda. SBA officials also said that they
implemented alternative procedures, such as preserving the order in
which applicants from Puerto Rico submitted their applications while they
gathered additional information. Furthermore, officials noted that some of
the delays were related to the local tax authorities.

We previously noted that applicants from territories generally applied
later. However, the discrepancy between award rates for U.S. territories

63GAO, Small Business Administration: Disaster Loan Processing Was Timelier, but
Planning Improvements and Pilot Program Evaluation Needed, GAO-20-168 (Washington,
D.C.: Feb. 7, 2020).

Page 44 GAO-22-105442 Restaurant Revitalization Fund
and states indicates that applicants from territories may have faced
additional processing delays. For example, applicants in Rhode Island
had a median application date of May 11, 2021, and about 30 percent
received awards. Applicants in Puerto Rico had a median application date
of May 12, 2021, but 15 percent received awards.

SBA’s RRF implementation plan included the equitable distribution of
funds as one of the program’s goals. As of June 2022, almost all RRF
funds had been awarded. Remaining funds must be awarded based on
the order in which applications were received. Thus, it is too late to
remediate weaknesses in RRF control design that may have adversely
affected applicants from U.S. territories. However, there may be lessons
learned for SBA on how to mitigate a similar issue for future programs. A
review of how the tax and bank account verifications—as well as other
controls—may have adversely affected RRF applicants from the U.S.
territories could help inform SBA’s design and implementation of similar
controls in future programs.

To oversee RRF recipients, SBA requires recipients to report annually on
SBA Has Limited their use of funds and has started reviewing a sample of awards.
Post-Award Controls However, SBA’s efforts to enforce compliance with its annual reporting
requirement for recipients were limited and its reporting form does not ask
for Identifying for operating status (information that could lead to return of unused
Fraudulent or funds). The agency has not used techniques such as data analytics to
proactively identify awards for indicators of potential fraud. SBA also has
Ineligible Recipients not fully leveraged its RRF program data or DOJ and OIG information to
detect potentially fraudulent awards. Lastly, SBA does not have a plan to
promptly take action on all awards flagged for potential fraud or
ineligibility.

Page 45 GAO-22-105442 Restaurant Revitalization Fund
SBA Has Not Enforced To monitor that RRF recipients spent their awards on eligible expenses,
Compliance with SBA developed an annual reporting form (see fig. 15). 64 SBA’s program
Reporting Requirements guidance describes the reporting requirement and SBA communicated it
directly to potential applicants in webinars prior to program launch. SBA
or Collected Information officials said they launched the reporting portal in October 2021 and
on Recipient Operating subsequently emailed recipients to inform them of the requirement.
Status
Figure 15: Illustrative Example of a Completed Post-Award Report for the
Restaurant Revitalization Fund

Compliance with Annual As of June 2022, about 32 percent of RRF recipients had missed the first
Reporting Efforts reporting deadline (December 31, 2021) and SBA has taken limited steps
to enforce compliance. In December 2021, SBA emailed recipients to
remind them of the requirement. Since the deadline, SBA officials said

64RRF program guidance states that recipients must submit the reports annually until they
have spent their entire award, or by March 11, 2023 when the program ends (whichever
comes first). The deadline to submit the final use of fund reports is April 30, 2023.
Recipients must report award use for the following categories of eligible expenses (based
on ARPA): (1) payroll (including paid sick leave); (2) rent or mortgage payments; (3)
utilities; (4) debt service; (5) construction of outdoor seating; (6) maintenance; (7)
supplies; (8) food and beverage (including raw materials); (9) covered supplier costs; and
(10) business operating expenses.

Page 46 GAO-22-105442 Restaurant Revitalization Fund
they have emailed and called recipients to encourage reporting and
asked industry associations to alert their members.

SBA’s RRF reporting form states that if a recipient fails to meet reporting
deadlines, SBA may require the return of some or all of the RRF funds.
Furthermore, federal internal control standards state that management
should use quality information to achieve objectives, including obtaining
data on a timely basis so that they can be used for effective monitoring. 65

In March 2022, SBA officials said they learned that an issue with the
reporting portal could have affected reporting rates. Specifically, the portal
would not allow recipients to submit their reports unless they certified they
had spent their entire award. Thus, recipients who still had remaining
funds could not complete the report. SBA officials said they were working
with the Office of Management and Budget to update the reporting form
and portal.

While updating the reporting portal may improve the response rate, SBA
still does not plan to take timely action to address recipients who have not
submitted their 2021 reports. SBA’s RRF program guide states that
recipients must submit their first reports by December 31, 2021. 66 Yet
SBA officials stated that they do not consider recipients to be
noncompliant until final reports are due (in April 2023). SBA’s internal
guidance to staff on reviewing recipients’ reports does not include
information on when to designate recipients as noncompliant with the
requirement or how to handle recipients who fail to submit reports.

Without enforcing compliance with the annual reporting requirement—and
developing policies and procedures on how and when to do so—SBA will
be limited in its ability to monitor how RRF funds have been spent and to
obtain reasonable assurance that recipients have complied with program
requirements.

Information on Recipient SBA does not require RRF recipients to report their operating status
Operating Status (open or permanently closed)—information that relates directly to fund
recoverability. ARPA states that recipients whose businesses
permanently close during the program period (which ends on March 11,

65GAO-14-704G.

66Restaurant Revitalization Funding Program Guide as of April 28, 2021.

Page 47 GAO-22-105442 Restaurant Revitalization Fund
2023) before expending their entire award must return the unused funds
to SBA. 67

In December 2021 and February 2022, SBA officials stated they had no
plans to track if recipients were still open or to change the annual
reporting forms to add a question on operating status. SBA’s internal
guidance on post-award report reviews states that if a recipient closed
before awarded funds were spent, then SBA would notify the recipient to
return the unused funds. However, SBA’s internal guidance does not
explain how SBA would become aware that a recipient had closed.

SBA designed the use-of-funds report to minimize the reporting burden
on recipients. However, incorporating a question about operating status
could help SBA document compliance with the ARPA provision about
permanently closed recipients. Furthermore, the post-award reporting
form is very short, and only asks recipients to report how they have spent
their award to date with no additional questions, as shown in figure 15.
Three recipients we interviewed said that the post-award report was easy
to complete and not a burden, particularly in comparison to other relief
programs and considering the amount of funding they received.
Additionally, options such as requiring only a representative sample of
recipients to provide supporting documentation to verify the information
could minimize other recipients’ reporting burden.

Federal internal control standards state that management should use
quality information to achieve objectives, including obtaining data on a
timely basis so that they can be used for effective monitoring. 68

By not collecting information on operating status, SBA will not know if
RRF recipients have permanently closed before spending their entire
award, and thus will not know if recipients should have returned unused
funds. If SBA waits until March 2023 (when the program closes) to collect
this information, it also may be more difficult to contact recipients and
obtain this information. Finally, by not taking steps to identify closed
recipients, SBA slows fund recovery and redistribution to open eligible
businesses (over 150,000 RRF applicants did not receive funding). SBA
officials said that all program funds expire in March 2023; thus, waiting

6715 U.S.C. § 9009c(c)(6).

68GAO-14-704G.

Page 48 GAO-22-105442 Restaurant Revitalization Fund
until then to take action would mean that any recovered funds could not
be redistributed.

SBA Has Not Used Data SBA has not used data analytics to identify potentially fraudulent
Analytics to Proactively awards. 69 During the application process, SBA collected a variety of data
Identify Fraudulent Awards from applicants, such as business characteristics, revenue, and tax
returns. SBA used these data to screen applications for potential fraud or
ineligibility. Yet, in February 2022, SBA officials told us they were not
analyzing data to detect potentially fraudulent recipients.

Data analytics, such as mining of RRF applicant and recipient data, could
identify trends related to potentially fraudulent awards. For example, we
found that RRF applicants not approved because of potential fraud were
more likely to be businesses that identified as sole proprietorships. Thus,
awards to these businesses could be considered at higher risk for fraud.
In addition, SBA officials said they have not reviewed RRF awards to
identify different businesses using the same address, an indicator of
potential fraud. We found instances in which multiple applicants used the
same business address or email address. For example, four businesses
all applied using the same business and email addresses and collectively
received over $15 million, with three businesses receiving $5 million each
(the maximum award amount). Our research of public records indicates
that these are owned or managed by the same entity. Post-award data
analytics could include identifying awards with such characteristics and
incorporating these higher-risk awards into SBA’s manual post-award
reviews, discussed below.

In addition, SBA matched applicant and recipient data from PPP to
screen RRF applicants (about 90 percent of RRF recipients also received
PPP loans). As discussed in the following section, SBA used some PPP
flags to identify recipients for further review. However, SBA does not have
a process to regularly match RRF recipients against recipients of its other
COVID-19 relief programs, which could detect potential fraud. For
example, if an EIDL loan recipient were flagged for potential fraud after

69Data analytics involves a variety of techniques to analyze and interpret data to facilitate
decision-making and may be used to identify patterns or trends, determine whether
problems are widespread and systemic in nature, and evaluate program performance and
outcomes. See GAO, Highlights of a Forum: Data Analytics to Address Fraud and
Improper Payments, GAO-17-339SP (Washington, D.C.: Mar. 31, 2017).

Page 49 GAO-22-105442 Restaurant Revitalization Fund
they also received an RRF award, the RRF award would not be similarly
flagged or reviewed for potential fraud.

According to GAO’s Fraud Risk Framework, federal program managers
should take steps to detect fraud, including conducting data analytics and
matching activities. 70 These techniques can enable programs to identify
potential fraud or improper payments, thus assisting programs in
recovering these dollars. The International Public Sector Fraud Forum
has developed principles for effective fraud control in emergency
management contexts. 71 They include carrying out targeted post-event
assurance to look for fraud.

SBA officials told us they do not need to conduct such analyses of RRF
awards because they believe the program’s pre-award controls are
sufficiently robust. Officials noted that the pre-award controls prevented
over 30,000 potentially fraudulent applications from being funded and
they did not believe there are major residual fraud risks in the program. In
June 2022, officials said that because they consider RRF to be low-risk,
they do not need to conduct data analytics.

However, we have noted that because of the government’s need to
quickly provide funds and other assistance to those adversely affected by
the pandemic, federal relief programs generally are vulnerable to
significant risk of fraudulent activities. 72 And as previously discussed, in
the report on SBA’s 2021 consolidated financial statements, SBA’s
independent auditor recommended that SBA perform a thorough review
of RRF awards issued and identify potentially ineligible recipients,
especially for recipients with flagged PPP loan guarantees. 73 Moreover,
the agency has the capability to perform data analytics for RRF because
it conducts ongoing data analysis of PPP to identify potentially fraudulent
or ineligible loans. Furthermore, even basic data analytics steps—such as
identifying awards using duplicate addresses and incorporating them into

70GAO-15-593SP.

71The forum noted that the principles also can be applied to any other areas where
governments need to implement services quickly. International Public Sector Fraud
Forum, Fraud in Emergency Management and Recovery: Principles for Effective Fraud
Control (February 2020). The forum was established in 2017 by government officials from
Australia, Canada, New Zealand, the United Kingdom, and the United States. Its goal is to
share best and leading practices to reduce the risk and harm of fraud and corruption in the
public sector.
72GAO-20-625.

73Independent Auditors’ Report on SBA’s FY 2021 Financial Statements, 22-05.

Page 50 GAO-22-105442 Restaurant Revitalization Fund
post-award reviews—would help SBA to ensure greater program integrity.
Using data analytics to review RRF program awards would enhance
SBA’s ability to identify potentially fraudulent recipients.

SBA Has Not Fully SBA has not fully used law enforcement data to identify potential fraud in
Leveraged Enforcement the RRF program. As previously noted, SBA used PPP data to verify RRF
applicant identities and award amounts (approximately 90 percent of RRF
Information
recipients also received PPP loans). But as of February 2022, SBA
officials told us they were not cross-checking data on RRF recipients
against information on suspicious PPP borrowers provided by DOJ or
OIG (according to SBA officials, DOJ and OIG regularly provide them with
information on suspicious PPP borrowers). In June 2022, SBA officials
noted that they follow a set of procedures to use PPP hold code data to
identify potential fraud in RRF recipients, but SBA did not provide
documentation of these procedures.

According to GAO’s Fraud Risk Framework, federal program managers
should work with stakeholders (including enforcement entities) to share
information on fraud risks and schemes. 74 And as previously discussed,
effective fraud control in emergency management contexts includes
carrying out targeted post-event assurance. 75

As with the assessments we discussed previously, SBA officials said they
do not conduct this analysis because they believe the program’s pre-
award controls are sufficiently robust and they do not believe there are
major residual fraud risks in the program. However, by leveraging
enforcement information on potential fraud from other SBA COVID-19
relief programs, SBA could better detect and mitigate fraud risk and
potential RRF fraud.

SBA Reviews a Sample of In March 2022, SBA started contacting 10,050 recipients (about 10
RRF Recipients but Does percent of the total) to manually review their awards, but it has not
developed a plan to promptly act on all potentially fraudulent or ineligible
Not Act Promptly on
awards.
Potential Fraud
SBA Based Review Selection SBA selected recipients for manual review based on flags from other
in Part on System Flags reviews or through sampling (see table 8).

74GAO-15-593SP.

75Fraud in Emergency Management and Recovery: Principles for Effective Fraud Control.

Page 51 GAO-22-105442 Restaurant Revitalization Fund
• Flagged awards. The post-award review sample includes three
categories of RRF awards that were flagged for various reasons. After
awards were made, SBA staff identified potentially ineligible recipients
by conducting searches using keywords, such as clubs and hotels.
Through these searches, they identified 8,900 potentially ineligible
awards. Staff then reviewed the recipients’ supporting documentation
and searched for the businesses online. After this additional research,
staff had about 1,300 awards that appeared to be ineligible and
included these awards in the sample. SBA also included recipients
with a flagged PPP loan or other flags in the payment system,
including those that had applied through the POS vendor with a
technical error (discussed earlier in the report). SBA officials said that
additional awards flagged after March 2022 would be added to the
sample for later reviews.
• Random samples. SBA worked with a contractor to develop an
improper payment testing sample in compliance with federal
guidelines. 76 The sample was stratified among SBA’s different risk
tiers for RRF awards and recipients were randomly selected based on
this stratification. In addition, SBA randomly selected 5,100 awards
from the remaining population. SBA added this additional random
sample to reach a sample size of 10 percent of awards.

76In accordance with the Payment Integrity Information Act of 2019 and Office of
Management and Budget Circular A-123 Appendix C, SBA must annually review all
programs and activities that may be susceptible to significant improper and unknown
payments. In general, SBA must report improper and unknown payment amounts,
program improper payment rates, and activities undertaken to reduce improper payments.
For its sampling methodology, SBA used a 10 percent estimate based on Circular A-123
guidance that a program’s improper payment rate should not exceed 10 percent. In April
2022, SBA officials said they will conduct a risk assessment later in fiscal year 2022 to
determine if RRF is susceptible to improper payments (as is required by federal
guidelines). If SBA determines the program is susceptible to improper payments, it will
report an improper payment estimate in fiscal year 2023. See Office of Management and
Budget, Circular A-123 Appendix C: Requirements for Payment Integrity Improvement,
OMB-21-19 (Washington, D.C.: Mar. 5, 2021).

Page 52 GAO-22-105442 Restaurant Revitalization Fund
Table 8: Number and Categories of RRF Awards Selected for Manual Review

Category Description Number of awards
Flagged awards RRF award with flag The award was flagged in SBA’s payment system 3,926
as having an issue.
PPP loan with a flag A PPP loan associated with the RRF recipient had a 241
flag potentially relevant to the award.
Eligibility flag SBA identified the RRF award as having potential 399
eligibility issues.
Random samples Statistical sample Statisticians identified awards as part of a 384
statistically valid improper payment testing sample.
Internal sample Awards were randomly selected from remaining 5,100
population.
Total 10,050

Legend: PPP = Paycheck Protection Program; RRF = Restaurant Revitalization Fund; SBA = Small Business Administration
Source: SBA. | GAO-22-105442

Note: According to SBA documentation, some awards fell into multiple categories and each award
was only grouped with its primary category.

SBA will initiate the manual review only when a recipient reports having
spent its entire award. (In other words, if in December 2021, a selected
recipient reported using 50 percent of award funds, SBA would not
contact that recipient until it reported spending the entire award.) SBA
officials said they determined this sampling method would use agency
resources more efficiently.

SBA contacts the recipients selected for manual review through the online
RRF portal and asks them to provide documentation supporting their use
of awards (such as payroll, paid invoices, or proof of rent or mortgage
payments). SBA staff review the documentation for any indications of
fraud and confirm it supports all eligible expenses reported. If a recipient
cannot provide supporting documentation for some or all of the expenses,
SBA will initiate steps to recover the award.

SBA Does Not Have a Plan to Almost half of the awards selected for review were flagged for potential
Respond Promptly to fraud or ineligibility, but SBA does not review all such awards promptly. In
Suspicious Awards June 2022, SBA officials said they will begin manually reviewing flagged
awards that were submitted through the POS vendor with a technical
error (discussed earlier in the report). However, according to SBA’s RRF
post-award review process procedures, the remaining flagged awards are
only reviewed when the recipients certify they have spent their entire
award or after they submit their final use-of-funds report (which will be

Page 53 GAO-22-105442 Restaurant Revitalization Fund
due in April 2023). Thus, SBA might not investigate a potentially
fraudulent or ineligible award until after April 2023.

SBA has referred few suspicious RRF awards to its OIG, according to
SBA OIG officials. After the initial application period in May and June
2021, OIG officials said OCA sent them data on more than 30,000
applications denied on account of suspected fraud. OIG officials said they
did not take further action, as the current priority is to investigate potential
fraud related to disbursed funds. However, they told us the information
did not specify why the applications had been flagged. In April 2022, SBA
OIG officials said they had received 19 formal SBA referrals of potential
RRF fraud through the SBA OIG hotline (some of which came from
recipients’ banks). In June 2022, SBA officials stated they had referred 46
cases of potential RRF fraud to the OIG. However, SBA’s own data
indicate almost 400 RRF awards were flagged for potential fraud.

OIG officials said they generally rely on SBA program management to
identify potential fraud and conduct initial research into suspected fraud.
OIG officials said they also rely on program offices to pursue payment
recoveries to mitigate fraud the OIG is unable to investigate. OIG officials
said that they have had relatively less contact with SBA on RRF fraud
compared to the other pandemic relief programs. OIG officials also noted
that the EIDL and SVOG programs have dedicated fraud mitigation teams
and that PPP relies on lenders to conduct oversight of PPP borrowers.
SBA officials also noted that they proactively identify potentially fraudulent
PPP loans for referral to the OIG through data analysis (including
automated screenings and aggregate portfolio reviews).

OCA officials said that RRF does not have a dedicated fraud mitigation
team but that a team in OCA’s Office of Financial Program Operations
tracks potential PPP and RRF fraud cases that SBA’s analysts, other
government agencies, lenders, or victims of identity theft have reported.
The team coordinates with investigative agencies to flag potentially
fraudulent RRF awards, with the goal of preventing the flagged recipients
from receiving additional SBA funds. RRF program staff said that they
sometimes will ask recipients to return an award if they find an improper
payment. However, as noted previously, staff generally only review
awards for improper payments upon submission of the final use of funds
report, and not when they first learn about issues with the award.

While RRF does not have standard operating procedures of its own, the
procedures for another SBA program providing assistance to
individuals—the Disaster Assistance Program—state that that SBA

Page 54 GAO-22-105442 Restaurant Revitalization Fund
personnel should take immediate action in cases of suspected fraud. 77 In
addition, GAO’s Fraud Risk Framework states that federal managers who
effectively manage fraud risks develop a plan outlining how the program
will respond to identified instances of fraud and ensure the response is
prompt and consistently applied. 78 The framework also says effective
managers refer instances of potential fraud to the OIG or other
appropriate parties for further investigation, and collaborate and
communicate with the OIG to align efforts to address fraud.

SBA officials said they do not plan to investigate all RRF recipients
flagged for potential fraud or ineligibility until recipients certify that all
funds have been expended or until after recipients submit their final
reports. This is to avoid having to examine recipients more than once. But
by not taking prompt action to respond to flagged RRF recipients,
potential RRF fraud and improper payments could go uninvestigated until
after final reports are due (on April 30, 2023). In addition, SBA’s lack of
timely action on potentially fraudulent awards may slow fund recovery and
also prevent redistribution to eligible businesses in need of assistance
(because all remaining RRF funds will expire in March 2023).

SBA expeditiously implemented RRF and used lessons learned from
Conclusions previous emergency programs (such as PPP) to improve program design
and increase safeguards. For instance, the agency emphasized pre-
award controls to prevent over 30,000 potentially fraudulent or ineligible
applications from receiving awards. Since then, SBA instituted a recipient
reporting requirement and has started to review 10 percent of awards.
However, our work suggests a more balanced approach toward oversight,
using both pre- and post-award controls, is warranted.

SBA could improve its oversight of the RRF program in the following
areas:

• Assessment of pre-award controls. We identified weaknesses in
SBA’s design and execution of some pre-award controls, but as of
June 2022, SBA had not assessed them. SBA officials stated they
planned to continue to make awards until the remaining $180 million

77As of April 2022, SBA did not have standard operating procedures for RRF. We
reviewed the standard operating procedures for SBA’s Disaster Assistance program
because, like RRF, it is an emergency program in which SBA provides direct assistance to
individuals. Small Business Administration, Disaster Assistance Program, SOP 50 30 9
(Washington, D.C.: May 31, 2018).
78GAO-15-593SP.

Page 55 GAO-22-105442 Restaurant Revitalization Fund
in program funds were spent. Conducting and documenting an
assessment of these controls would allow SBA to determine if they
worked as expected. The assessment could also provide SBA with
the opportunity to document changes made to its planned control
framework during implementation, such as issues with IRS verification
and risk tier assignments. Taking steps to strengthen pre-award
controls could help ensure that remaining funds are awarded to
eligible applicants, and could inform future programs.
• Applications from U.S. territories. The design of some pre-award
controls—such as verifying applicants’ tax information and bank
accounts—caused delays in reviewing applications from businesses
in U.S. territories. Because funding was limited, the delays may have
disadvantaged these applicants. Assessing how the control design
affected applicants in U.S. territories and identifying potential
alternatives could help SBA mitigate this issue in future programs.
• Overdue post-award reports. As of June 2022, about one-third of
RRF recipients had not met the first deadline for reporting on how
they used awards. But SBA officials said they will only consider
recipients noncompliant if they miss the final reporting deadline in
April 2023. Timely enforcement of the reporting requirement would
provide SBA with more relevant and complete data to monitor the
program and potentially recover funds not appropriately used.
• Reporting of operating status. SBA’s post-award reporting form
does not ask recipients about their operating status (although ARPA
stipulates that recipients whose businesses close before expending
their entire awards must return unused funds). By collecting this
information, SBA would have greater assurance that recipients
complied with award conditions.
• Data analytics. SBA has taken limited steps to analyze program data
to detect potentially fraudulent awards. SBA collected a great amount
of data during the application review process, and also has
information on characteristics of fraudulent applications. By leveraging
these data, SBA can proactively identify suspicious awards.
• Use of enforcement information. As of June 2022, SBA was not
leveraging DOJ or OIG information on suspected fraud in other SBA
pandemic relief programs. Leveraging these data would allow SBA to
more effectively identify potential fraud among RRF recipients.
• Fraud response plan. As of June 2022, SBA was not taking timely
action to respond to all awards flagged for potential fraud or
ineligibility. Developing a plan to respond to such awards—including
coordinating with the OIG—could help the agency address potentially

Page 56 GAO-22-105442 Restaurant Revitalization Fund
fraudulent or ineligible awards in a more timely and consistent
manner.
By taking such steps to proactively identify fraudulent or ineligible award
recipients, SBA would be better positioned to recover RRF funds before
the program closing date and redistribute them to eligible businesses in
need of assistance—thus expanding the reach of the program.
Furthermore, if Congress decided to use RRF again, incorporating these
steps would help SBA promote program integrity.

We are making the following seven recommendations to SBA:
Recommendations for
Executive Action The Associate Administrator for the Office of Capital Access should
conduct and document an assessment of the RRF pre-award controls
and address or mitigate deficiencies. (Recommendation 1)

The Associate Administrator for the Office of Capital Access should
assess how the design of RRF pre-award controls may have adversely
affected applicants from U.S. territories, and identify and document steps
to mitigate this issue for future programs. (Recommendation 2)

The Associate Administrator for the Office of Capital Access should
develop and implement policies and procedures for addressing RRF
recipients who do not meet annual reporting requirements.
(Recommendation 3)

The Associate Administrator for the Office of Capital Access should
enhance RRF post-award reporting procedures by adding requirements
for recipients to report their operating status. (Recommendation 4)

The Associate Administrator for the Office of Capital Access should
develop and implement data analytics across RRF awards as a means to
detect potentially fraudulent award recipients. (Recommendation 5)

The Associate Administrator for the Office of Capital Access should
develop, document, and implement procedures to use enforcement data
on suspected fraud in other SBA programs, such as PPP, to identify
potential fraud in RRF recipients. (Recommendation 6)

The Associate Administrator for the Office of Capital Access should
develop and implement a plan to respond to potentially fraudulent and
ineligible RRF awards in a prompt and consistent manner. This plan

Page 57 GAO-22-105442 Restaurant Revitalization Fund
should include coordinating with the OIG to align efforts to address fraud.
(Recommendation 7)

We provided a draft of this report to SBA for review and comment. In
Agency Comments written comments, which are summarized below and reproduced in
and Our Evaluation appendix III, SBA disagreed with five recommendations, partially agreed
with one, and agreed with one. Overall, SBA’s response echoes officials’
statements throughout our audit: that RRF controls align with industry
leading practices and thus do not need to be assessed, and that the
strength of the controls means there is limited fraud in the program and
agency officials do not need to take additional steps to identify potential
fraud.

In contrast, we maintain that our recommendations are still valid, as
described below.

• Assess pre-award controls. SBA disagreed with our
recommendation that it assess the RRF pre-award controls
(Recommendation 1). SBA described its pre-award control framework
and maintained that because the framework was based on industry
best practices, it does not need to be assessed. In our report, we
commend SBA’s pre-award control framework and noted the controls
prevented over 30,000 suspicious applicants from receiving awards.
However, we still believe there is value in SBA documenting an
assessment of its pre-award controls. For example, in our report, we
identified several control weaknesses, including fraudulent
applications stemming from a POS vendor and potentially ineligible
businesses that received awards. In its letter, SBA said that it has
started reviewing the awards from the problematic POS vendor. This
action is in line with this recommendation and a step in the right
direction. SBA could incorporate what it learns in these reviews into its
assessment of the pre-award controls.
Furthermore, documenting an assessment of these controls would be
valuable even if it found the controls worked as expected. Throughout
our work, we identified instances in which SBA did not document how
it adjusted the RRF control framework during program implementation
(for example, a risk tier designation was not described in any
documentation). Because SBA never updated its documentation, SBA
officials had to explain these differences in interviews. SBA’s
response mentions that it is already applying the RRF control
framework to other programs. But if SBA wished to apply the RRF
pre-award control framework to a future program, it would be difficult
for future program officials to do so based on current documentation

Page 58 GAO-22-105442 Restaurant Revitalization Fund
and without any description of how controls were modified or an
assessment of how they worked.
Finally, SBA noted that it has already begun the manual post-award
review described in the report. This effort can inform a pre-award
controls assessment. For example, if SBA finds a fraudulent or
ineligible award, it could subsequently assess why it was not caught
by the pre-award controls. Upon completing the manual reviews, SBA
could identify changes to the control framework that would benefit
future programs. We believe that taking these steps would provide
SBA with greater assurance that the RRF controls worked as
expected and that the controls could be used for future programs.

• Control framework and U.S. territories. SBA disagreed with our
recommendation that it assess how its tax verification pre-award
control may have adversely affected applicants from U.S. territories
(Recommendation 2). In its response, SBA noted 75 percent of
applicants from Puerto Rico triggered a manual bank account
verification, which took longer than automated verifications. We agree
with SBA’s point that bank account verification contributed to the
discrepancies; we therefore modified our recommendation to focus on
the RRF pre-award controls more broadly. For example, SBA could
examine why 75 percent of applicants from Puerto Rico had to have
their bank accounts manually verified, how long such verifications
took, and if the agency could have instituted alternative procedures to
mitigate any negative impacts.
SBA also noted that in a February 2020 report about SBA disaster
loans for damage from Hurricane Maria, we did not make any
recommendations regarding territory tax processing challenges. 79
However, we cited this report as an example of a time when SBA
instituted alternative procedures to address challenges verifying
territory residents’ tax information. As we describe here and in the
2020 report, SBA granted applicants from Puerto Rico conditional
approval for disaster loans while it took additional time to verify tax
information.
While OCA has said it worked with Office of Disaster Assistance to
process RRF applicants from U.S. territories, it did not implement the
alternative procedures previously used by that office. For example,
the RRF documentation does not mention conditional approval or
other ways to mitigate territorial processing delays. For part of this
controls assessment, SBA could assess if the alternative procedures

79GAO-20-168.

Page 59 GAO-22-105442 Restaurant Revitalization Fund
described in our 2020 report (or other options) would have helped
RRF applicants, and trade-offs to instituting such alternatives.
• Overdue post-award reports. SBA disagreed with our
recommendation that the agency implement policies and procedures
for RRF recipients who do not meet annual reporting requirements
(Recommendation 3). In its response, SBA said that ARPA did not
mandate a post-disbursement review process. However, SBA chose
to institute an annual reporting requirement for RRF recipients. It also
included a clear warning on its OMB-approved annual reporting form
(just above the signature line) that the agency may require recipients
who “fail to submit reports by reporting deadlines” to return some or all
of their funds.
SBA’s response noted that its post-award reporting procedures
address recipients who fail to provide requested documents, and
situations in which SBA cannot verify the use of funds. However, SBA
does not have criteria or a definition for when a recipient has failed to
meet the annual reporting requirement (e.g., 1 month overdue) or
consequences for doing so. Finally, as of June 2022 (6 months after
the original deadline), almost one-third of recipients have not
submitted their 2021 annual reports, and SBA is unaware of how
these recipients are using their awards.
We believe instituting clear policies about when a recipient has
missed the annual reporting deadline and procedures for how to
handle overdue reports (including when the agency will pursue fund
recovery) would help SBA improve the response rate and have better
assurances that recipients are spending funds in eligible categories.
• Use of enforcement data. SBA disagreed with our recommendation
that it develop procedures to use enforcement data on suspected
fraud in other SBA programs to identify potential RRF fraud
(Recommendation 6). In its response, SBA said it is currently
following procedures to utilize PPP hold code data to identify potential
fraud in RRF recipients, but as of June 27, 2022, SBA had not
provided documentation or additional information about the
procedures. Thus, we modified our recommendation language to
include that SBA document these procedures.
Secondly, SBA said it was not cross-checking RRF recipients with
EIDL, specifically because we and the OIG previously reported on
EIDL’s control weaknesses. However, we believe cross-checking RRF
recipients with EIDL recipients would be useful. Fraudsters may
attempt to defraud multiple programs and re-use information across
programs. For example, as we describe in the report, the alleged RRF

Page 60 GAO-22-105442 Restaurant Revitalization Fund
fraudster that the DOJ is prosecuting previously applied for EIDL and
was denied. The defendant then used the same address on his RRF
application and received over $8 million. SBA could regularly cross-
check addresses, emails, or other identifiers associated with flagged
EIDL, SVOG, or PPP recipients with RRF recipients.
Finally, we know some RRF recipients have been flagged in other
programs: SBA’s independent auditor found that some RRF recipients
also had PPP loans that were flagged and recommended SBA
thoroughly review all RRF awards. 80 SBA incorporated RRF recipients
with flagged PPP loans into its manual post-award reviews, but SBA
has not provided documentation that it regularly conducted such
cross-checks. We maintain that regularly cross-checking RRF
recipients with enforcement information from other SBA programs
would help SBA identify potential fraud in the RRF program and
ensure program integrity.
• Timely fraud response and OIG coordination. SBA disagreed with
our recommendation to develop a plan to address fraudulent and
ineligible awards in a timely and consistent manner (Recommendation
7). In its response, SBA noted that it will soon start to manually review
all flagged awards that originated from the POS partner with a control
weakness, even those that have not certified spending their entire
RRF award. We commend SBA for this change in its procedures—
when we interviewed SBA officials in March 2022, they maintained
they would only review awards flagged for potential fraud upon
submission of the final report.
We still believe that SBA should change its procedures to manually
review any award flagged for potential fraud or ineligibility shortly after
it is flagged and not when the recipient certifies spending the entire
award (which could be almost 2 years after the award was disbursed).
Doing so could help SBA to recover funds in a timely manner so that
they could be redistributed to eligible applicants in need of assistance
(under current procedures, SBA would not be able to redistribute
awards recovered after March 2023, when the funds expire).
SBA also disagreed with the part of our recommendation to
coordinate with the OIG. SBA listed the ways it has worked with the
OIG on RRF, including responding to OIG requests for information (as
would be expected) and referring 46 potentially fraudulent awards to
the OIG. Regardless, OIG officials told us that they have had relatively
less contact with RRF program officials than with those from other
pandemic relief programs and that some information SBA initially
80Independent Auditors’ Report on SBA’s FY 2021 Financial Statements, 22-05.

Page 61 GAO-22-105442 Restaurant Revitalization Fund
provided on RRF was unclear. OIG officials also said that for other
programs, sometimes SBA staff conduct initial research into
suspected fraud or pursue recoveries of smaller amounts, and that
such actions were useful to the OIG during a time of increased
workload.
Furthermore, SBA did not mention any specific coordination on how it
should refer suspected RRF fraud to the OIG. Through such
coordination, OIG and SBA officials could discuss when SBA should
refer suspected RRF fraud to the OIG, information SBA should
provide the OIG, and actions SBA could take on its own (such as
initial research or pursuing recoveries of smaller awards).
Coordinating on these specific actions would help ensure SBA
provides the OIG with useful information and help the OIG use its
resources efficiently.
SBA partially agreed with our draft recommendation to use data analytics
to identify potentially fraudulent RRF recipients (Recommendation 5). In
its response, SBA said the agency’s Fraud Risk Management Board had
identified RRF data analytics as a possible project. SBA also noted that
some data analytics had already occurred and specifically pointed to its
analysis of awards to identify those that are potentially ineligible. We
believe this is a step in the right direction and that a similar analysis to
identify potentially fraudulent awards would be beneficial. Such analysis
could involve basic steps, such as identifying recipients that used
duplicate business addresses or recipients with characteristics similar to
those of applicants denied due to suspected fraud (such as sole
proprietorships). SBA could then include a sample of these awards in its
manual reviews.

SBA agreed with our recommendation that it institute procedures for RRF
recipients to report on their operating status (Recommendation 4).

SBA’s letter also included an appendix that elaborated on the agency’s
disagreements with our recommendations and other aspects of the
report. For example, SBA included additional detail on public records
checks for sole proprietorships and described a bank account status
review team. SBA also provided data on applicants from Puerto Rico.
SBA noted that the percentage of applicants from Puerto Rico at the
stage of IRS verification was lower than applicants from two other states.
However, in the two states SBA selected, approximately 30 percent of
applicants had received awards, while 12 percent of applicants from
Puerto Rico had. Thus, we do not believe this is a fair comparison. The
data SBA provided also highlight the challenges applicants from Puerto

Page 62 GAO-22-105442 Restaurant Revitalization Fund
Rico faced with bank account verification: approximately 17 percent of
applicants from the two states were at the bank account verification stage
when RRF funds were exhausted, compared to 28 percent of applicants
from Puerto Rico.

The appendix also contained a number of technical comments, which we
reviewed and incorporated as appropriate.

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

If you or your staff have any questions about this report, please contact
me at (202) 512-8678 or shearw@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.

William B. Shear
Director, Financial Markets and Community Investment

Page 63 GAO-22-105442 Restaurant Revitalization Fund
List of Committees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Patty Murray
Chairwoman
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Benjamin Cardin
Chairman
The Honorable Rand Paul
Ranking Member
Committee on Small Business and Entrepreneurship
United States Senate

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

Page 64 GAO-22-105442 Restaurant Revitalization Fund
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives

The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives

The Honorable Nydia M. Velázquez
Chairwoman
The Honorable Blaine Luetkemeyer
Ranking Member
Committee on Small Business
House of Representatives

The Honorable Richard E. Neal
Chairman
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

Page 65 GAO-22-105442 Restaurant Revitalization Fund
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology

Methodology

This report examines (1) how the Small Business Administration (SBA)
implemented the Restaurant Revitalization Fund (RRF), (2) the
characteristics of RRF recipients, (3) SBA’s steps to manage risks for
RRF and the extent to which these steps align with leading practices, and
(4) SBA’s efforts to monitor recipients, including identifying fraudulent or
ineligible award recipients.

For the first, second, and third objectives, we analyzed SBA’s data on
RRF applicants (which includes those who applied for but did not receive
funding) and recipients.

• Objective 1. We analyzed applicant and recipient data to determine
the number of applications received and approved per day, the
number of applications received through different methods (SBA’s
portal or external vendors), the amounts requested, and processing
times.
• Objective 2. We analyzed applicant data to describe funding amount
requested, demographic information on the business owner, business
location, business type, 2019 gross receipts, and whether the
business participated in other SBA pandemic relief programs. From
the recipient data, we analyzed funding amount requested,
demographic information on the business owner, business location,
and business types.
• Objective 3. We analyzed the RRF applicant and recipient data to
identify potential control weaknesses, such as duplicate business
locations and tax identification numbers and awards to potentially
ineligible businesses. We also analyzed applicant data to identify the
reasons applications were denied, such as potential fraud or
ineligibility. In addition, we compared applicant and recipient data to
other datasets (described below) to assess RRF pre-award controls.

For these three objectives, we assessed the reliability of SBA’s RRF
applicant and recipient data by reviewing related documentation,
conducting testing to check for outliers and errors, and interviewing
agency officials. We determined these data were sufficiently reliable for
describing trends in application receipt and processing; recipient
characteristics such as business type and location, self-reported
characteristics, and revenue; and denial reasons.

In addition to the data analysis, for the first objective, we reviewed SBA
documentation and interviewed agency officials. Specifically, we reviewed
the RRF implementation plan, program guide, and applicant outreach

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Appendix I: Objectives, Scope, and
Methodology

materials. To describe how SBA plans to assess the performance of the
RRF program, we reviewed SBA’s RRF logic model (which includes the
agency’s desired outcomes for the program and the data it will use to
assess progress toward the outcomes) and interviewed SBA officials
about these efforts.

We also interviewed representatives from seven industry associations
representing restaurants, other eligible businesses, and relevant
stakeholders to obtain their perspectives on SBA’s implementation of the
program and their members’ experiences with the application process.
We selected associations that met at least two of the following criteria:
represented different sectors of eligible businesses, had testified about
RRF or had significant information about RRF on their websites, and had
been consulted by SBA when implementing RRF. We interviewed or
obtained written responses from representatives of the American Craft
Spirits Association, Distilled Spirits Council of America, Independent
Restaurant Coalition, National Federation of Independent Businesses,
National Food Truck Association, National Restaurant Association, and
United States Hispanic Chambers of Commerce. We also requested
interviews with eight other associations that met our criteria, but they
declined our requests. For our interview with the American Craft Spirits
Association, we interviewed three members who received RRF awards.
These views are not generalizable to other associations or all funding
recipients but offer important perspectives.

For the second objective, in addition to analyzing RRF applicant and
recipient data, we used the Census Bureau’s 2019 Statistics of U.S.
Businesses data to estimate the number of restaurants per state
potentially eligible for RRF. Specifically, we designated “total” restaurants
in each state as firms with 500 or fewer employees and a North American
Industry Classification System code definition of “Food Services and
Drinking Places” (NAICS 722) from the most recent County Business
Patterns data from the Census Bureau. While these data do not align with
all the eligibility criteria for RRF recipients—such as not having more than
20 locations and receiving 33 percent or more of their revenue from food
or drink—they provide reasonable estimates for comparing eligible
business populations at the state level. We assessed the reliability of the
census data by reviewing documentation and determined the data were
sufficiently reliable to estimate the number of eligible businesses per
state.

In addition to the state-level analysis for the second objective, we
compared median RRF award sizes to recipients across five major cities:

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Appendix I: Objectives, Scope, and
Methodology

Washington, D.C.; New York, New York; Boston, Massachusetts; San
Francisco, California; and Denver, Colorado. The RRF data contained
ZIP codes for recipient businesses. Recipient businesses’ awards were
included in our calculations if their ZIP code fell at least partially within the
U.S. Postal Service’s city-state boundary based on the Department of
Housing and Urban Development’s ZIP code to Core Based Statistical
Area crosswalk.

For the third objective, to examine SBA’s RRF risk management, we
analyzed RRF applicant and recipient data and compared these data with
SBA’s Shuttered Venue Operators Grant applicant and recipient data to
identify applicants and recipients of both programs. 1 For a sample of
applicants and recipients identified through our analysis, we conducted
additional research using public records to verify legal organization,
address, and operating status. We also analyzed SBA documentation,
such as application review plans and materials provided to application
reviewers.

We reviewed SBA’s fiscal year 2021 independent financial statement
audit and a report from the Pandemic Response Accountability
Committee. 2 We also reviewed a criminal complaint about an alleged
case of fraud in the RRF program. We interviewed SBA officials and the
contractor that developed the RRF portal about pre-award controls
designed to verify applicant identity and eligibility and mitigate fraud risk.
Finally, we compared SBA’s policies and procedures related to managing
risks against federal internal control standards and SBA’s goals for the
RRF program. 3

For the fourth objective, we reviewed SBA documentation on its post-
award controls, including recipient reporting requirements and forms,
improper payment testing plans, and an assessment of potentially
ineligible awards. We also reviewed SBA’s standard operating

1RRF applicants were ineligible for the Shuttered Venue Operators Grant program and
vice versa.
2Small Business Administration, Office of Inspector General, Independent Auditors’ Report
on SBA’s FY 2021 Financial Statements, 22-05 (Washington, D.C.: Nov. 15, 2021); and
Pandemic Response Accountability Committee, Small Business Administration Paycheck
Protection Program Phase III Fraud Controls (Washington, D.C.: Jan. 21, 2022).
3GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington. D.C.: Sept. 10, 2014).

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Appendix I: Objectives, Scope, and
Methodology

procedures regarding how another SBA program treats potential fraud. 4
In addition, we interviewed SBA officials to better understand post-award
controls and fraud detection methods, such as the agency’s use of data
analytics to identify potential fraud and referrals to the Office of Inspector
General. We also interviewed officials from SBA’s Office of Inspector
General regarding RRF fraud referrals. We compared SBA’s RRF
monitoring against federal internal control standards, GAO’s Fraud Risk
Framework, SBA’s standard operating procedures, and relevant
provisions in the American Rescue Plan Act. 5

4Small Business Administration, Disaster Assistance Program, SOP 50 30 9 (Washington,
D.C.: May 31, 2018). At the time of our review, SBA did not have standard operating
procedures for RRF.
5GAO, A Framework for Managing Fraud Risk in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 28, 2015); GAO-14-704G, and 15 U.S.C. § 9009c(c)(6).

Page 69 GAO-22-105442 Restaurant Revitalization Fund
Appendix II: SBA Procedures to Verify Appendix II: SBA Procedures to Verify
Restaurant Revitalization Fund Applicants Met

Restaurant Revitalization Fund Applicants
Eligibility Requirements

Met Eligibility Requirements
Restaurant Revitalization Fund (RRF) applicants were required to self-
certify that they met each of the program’s eligibility requirements. The
Small Business Administration (SBA) developed a variety of procedures
to verify this information, such as automated public records searches and
manual reviews of supporting documents (see table 9).

Table 9: RRF Eligibility Requirements and SBA Verification Procedures

Eligibility requirement Description SBA verification procedures
20 or fewer locations Businesses with more than 20 SBA staff generally relied on applicant-provided information
locations were ineligible. on number of locations and affiliates.
Bankruptcy status Businesses could not have filed for Automated public records searches to check bankruptcy
bankruptcy; may be under an approved status via SBA’s payment system.
reorganization plan.
Business type Eligible businesses were those where Automated controls to check IRS tax return data, which
patrons primarily assembled to be include codes from the North American Industry
served food or drink. Classification System, to support business type.
Certain business types, such as bakeries and inns, had to
submit documents to support that at least 33 percent of sales
were from on-site food or drink.
Organization type Certain organizations, such as Applicant self-certification could be supported with SBA’s
nonprofits and publicly traded entities, automated controls for other eligibility verification
were ineligible. requirements.
SVOG application RRF applicants could not also have a SBA staff conducted a data comparison and matching of
pending application or have received RRF and SVOG applicant records.
SVOG funds.
Operating status Permanently closed businesses were Automated public records search of information such as
ineligible. Secretary of State filings, unemployment insurance filings, or
state business license.
Award amount Between $1,000 and $5 million per SBA automatically verified award amounts using tax return
location (not to exceed $10 million for and PPP information. For larger awards, SBA staff reviewed
the applicant and any affiliated supporting documentation to confirm requested amount.
businesses).

Legend: IRS = Internal Revenue Service; PPP = Paycheck Protection Program; RRF = Restaurant Revitalization Fund; SBA = Small Business
Administration; SVOG = Shuttered Venue Operators Grant
Source: GAO analysis of SBA documentation. | GAO-22-105442

Page 70 GAO-22-105442 Restaurant Revitalization Fund
Appendix III: Comment from the Small
Appendix III: Comment from the Small
Business Administration

Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

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Appendix III: Comment from the Small
Business Administration

Page 82 GAO-22-105442 Restaurant Revitalization Fund
Appendix IV: GAO Contact and Staff
Appendix IV: GAO Contact and Staff
Acknowledgments

Acknowledgments

William B. Shear, (202) 512-8678 or ShearW@gao.gov
GAO Contact
In addition to the contact name above, Lisa Moore (Assistant Director),
Staff Miranda Berry (Analyst in Charge), Ranya Elias, Daniel Flavin, Toni
Acknowledgments Gillich, Nicholas Jones, Jill Lacey, Ying Long, John McGrail, Colleen
Moffatt Kimer, Barbara Roesmann, and Jena Sinkfield made significant
contributions to this report.

(105442)
Page 83 GAO-22-105442 Restaurant Revitalization Fund
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