Pandemic Darlings The pandemic economy, in original documents
Home Source documents Small Business Administration OIG (SBA OIG Spring 2022 Semiannual Report to Congress)

Small Business Administration OIG (SBA OIG Spring 2022 Semiannual Report to Congress)

Summary

The SBA Office of Inspector General's Spring 2022 Semiannual Report to Congress covers October 1, 2021 to March 31, 2022. In his April 29, 2022 message, Inspector General Hannibal "Mike" Ware reports $4.6 billion in joint monetary recoveries and savings for the period. He writes that OIG pandemic work had resulted in 366 indictments and 142 convictions related to the Paycheck Protection Program and EIDL as of December 2021, that work with the U.S. Secret Service led to the seizure of more than $1 billion stolen from the EIDL program, and that OIG helped financial institutions return another $3.1 billion to it. During the period OIG issued 9 reports with 70 recommendations, and its investigations resulted in 98 indictments and 85 convictions.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Small Business Administration OIG (SBA OIG Spring 2022 Semiannual Report to Congress).” Original at www.oversight.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/small-business-administration-oig-sba-oig-spring-2022-semiannual-repor-86015ab2d1/, SHA-256 36cb3940bf6386029d06cce37d3fe9a9f11348bd21d706237975b73121d9007c.

Full text

Semiannual Report to Congress

October 1, 2021 – March 31, 2022
                       U.S. Small Business Administration | Office of Inspector General


Message from the Inspector General

April 29, 2022
                           I am honored to submit our Semiannual Report to Congress for the first half
                           of fiscal year 2022. Every 6 months, we report to Congress our independent
                           oversight of the U.S. Small Business Administration (SBA), as required by law.
                           Two years have passed since the start of the Coronavirus Disease 2019
                           (COVID-19) pandemic economic crisis, and the SBA Office of Inspector
                           General (OIG) continues to provide independent and objective oversight. This
                           semiannual period we are reporting an unprecedented statistic: $4.6 billion
                           in joint monetary recoveries and savings. Without a doubt, this achievement
                           would not have been possible without our partner organizations.
                           We oversee the integrity, accountability, and performance of SBA and its
Hannibal “Mike” Ware       programs for the benefit of the American people. OIG works to improve SBA
Inspector General          programs by identifying key issues facing the agency, recommending
                           corrective actions, and promoting a high level of integrity.

Pandemic Response Oversight
Working with our law enforcement partners, we have set a standard of excellence in overseeing SBA
pandemic response for America’s small businesses. Independence and objectivity are critical in the
oversight of taxpayer funds allocated by the Coronavirus Aid, Relief, and Economic Security (CARES) Act
and subsequent Congressional economic stimulus funds and mandates.
We are deeply appreciative of the close partnership we have with the U.S. Attorneys across the nation
and in the Criminal and Civil divisions of the U.S. Department of Justice in Washington D.C. We have
sought to expand this partnership by detailing several attorneys to serve as Special Assistant U.S.
Attorneys to the Criminal Division Fraud and Public Corruption Section’s Market Integrity and Major
Frauds Unit. Our mission is momentous, and it requires a strategic allocation of resources.
SBA has expended more than a trillion dollars in lending authority and entrepreneurial assistance in the
wake of the pandemic. When SBA expedited relief to those in need, the agency relaxed internal
controls, increasing the risk of program fraud, abuse, and improper payments.
As the fraud landscape continues to unfold, we are collaborating across government to bring
wrongdoers to justice. OIG pandemic oversight and investigative work has resulted in 366 indictments
and 142 convictions related to the Paycheck Protection Program and Economic Injury Disaster Loan
(EIDL) as of December 2021. Our collaboration with the U.S. Secret Service has resulted in the seizure
of more than $1 billion stolen by fraudsters from the EIDL program. We also played a key role in
assisting financial institutions in the return of another $3.1 billion to SBA’s EIDL program.
Leveraging supplemental resources provided by Congress, we have published 20 reports on pandemic
oversight. We have issued dozens of recommendations for corrective action aimed at strengthening


                                                   Spring 2022 Semiannual Report to Congress | i
                    U.S. Small Business Administration | Office of Inspector General

internal controls so eligible small businesses receive the economic aid promised by Congress, not
fraudsters or other unscrupulous borrowers abusing taxpayer resources.
And this is just the tip of the iceberg. The true magnitude of fraud in SBA pandemic assistance
programs will be coming to light for many more years as these programs move into new stages. We
will continue to evaluate and recommend corrections for the most critical risks facing SBA, but
oversight of pandemic relief funds and combating fraud in these programs will be a top priority for
many years to come.

Our Work this Period
During the 6-month period from October 2021 to
March 2022, OIG issued 9 reports with 70
recommendations to improve SBA operations and
reduce fraud and unnecessary losses in agency
programs. In addition, OIG investigations resulted in
98 indictments and 85 convictions.
We are also keeping watch over government
contractors for business ethics, integrity, honesty,
and competency, ensuring taxpayer dollars are
spent efficiently according to intent.

OIG Staff Dedication and Success
I am proud that our OIG staff members are engaged change agents who set the standard for oversight
excellence in support of American small businesses and entrepreneurs. We carry out our duties and
responsibilities with integrity, never losing sight of this vision, committed to protecting the interests of
all American taxpayers by promoting positive change within SBA and across government.




Hannibal “Mike” Ware
SBA Inspector General




                                                   Spring 2022 Semiannual Report to Congress | ii
                              U.S. Small Business Administration | Office of Inspector General

Table of Contents
 SBA’s Top Management and Performance Challenges ...........................................................................................1

 Summary of OIG Oversight Work ............................................................................................................................2

 Pandemic Response Oversight .................................................................................................................................2

 Audits, Inspections, and Evaluations ......................................................................................................................2

     SBA’s Emergency EIDL Grants to Sole Proprietors and Independent Contractors (Report 22-01) ................2

     COVID-19 EIDL Program Recipients on the Department of Treasury’s Do Not Pay List (Report 22-06) ......3
     SBA’s Oversight of the Grant Recipient’s Implementation of the CARES Act Resource Partners Training
     Portal (Report 22-07) ...........................................................................................................................................3
     SBA’s Paycheck Protection Program Loan Review Processes (Report 22-09)...................................................4

 Notable Investigations ..............................................................................................................................................4

     Members of Los Angeles-Based Fraud Ring Sentenced in Multimillion-Dollar Scheme .................................4
     Oakland Woman Sentenced to 3 Years in Million Dollar Pandemic Relief Fraud ...........................................5

     Texas Man Sentenced to More Than 9 Years in COVID-19 Fraud and Money Laundering Scheme ..............5

     California Man Convicted in $27 Million PPP Fraud Scheme ..........................................................................5

     Two Florida Men Pled Guilty to $35 Million COVID-19 Relief Fraud Scheme ................................................5
     Man Who Evaded Justice Sentenced to Federal Prison for Pandemic Relief Fraud ........................................6

     Arizona Man Sentenced to 32 Months in Federal Prison for Fraudulent EIDL Applications .........................6

     Oregon Dentist Faces Federal Charges for Stealing About $8 Million in COVID-Relief Program Funds ......6

 Small Business Access to Capital.............................................................................................................................7

 Investigations ............................................................................................................................................................7

     Jury Convicts Five Former Officers and Employees of Banc-Serv Partners in $5 Million Scheme ................7

 Disaster Assistance Program ...................................................................................................................................9
 Contracting and Counseling Programs .................................................................................................................. 10

 Audits, Inspections, and Evaluations .................................................................................................................... 10

     SBA’s Business Development Assistance to 8(a) Program Participants (Report 22-08) ................................ 10

 Investigations .......................................................................................................................................................... 11

     Former Construction Company Owner Indicted for Defrauding Federal Program Intended for Service-
     Disabled Veteran-Owned Small Businesses ..................................................................................................... 11

 Agency Management............................................................................................................................................... 12

 Audits, Inspections, and Evaluations .................................................................................................................... 12

     SBA’s Controls Over Cash Contributions and Gifts, Fiscal Years 2021 and 2020 (Report 22-03) ................ 12

     Independent Auditors’ Report on SBA’s Compliance with DATA Act Reporting (Report 22-04) .................. 12
     Independent Auditors’ Report on SBA’s FY 2021 Financial Statements (Report 22-05) ............................... 13

 Other Significant OIG Activities ............................................................................................................................ 14

 Background Investigations Ensure Integrity ........................................................................................................ 14




                                                                               Spring 2022 Semiannual Report to Congress | iii
                             U.S. Small Business Administration | Office of Inspector General

Debarment and Other Administrative Enforcement Actions ............................................................................... 14

Stakeholder Presentations on PPP and EIDL Fraud............................................................................................ 14

Reviews of Proposed Agency Regulations, Operating Procedures, and Other Initiatives Lead to Improved
Program Controls ................................................................................................................................................... 14

Approval of Small Business Development Center Surveys .................................................................................. 14

OIG Hotline ............................................................................................................................................................. 15
Significant Increases............................................................................................................................................... 15

Organizational Overview ........................................................................................................................................ 16

U.S. Small Business Administration ..................................................................................................................... 16

Office of Inspector General ..................................................................................................................................... 16

Appendixes .............................................................................................................................................................. 19

Appendix A. Reporting Period Statistical Highlights ........................................................................................... 19

    Summary of OIG Dollar Accomplishments (dollars) ........................................................................................ 19

    Efficiency and Effectiveness Activities Related to Audit, Other Reports, and Follow-up Activities ............. 19
    Indictments, Convictions, and Case Actions .................................................................................................... 19

    SBA Personnel Actions Taken as a Result of Investigation ............................................................................ 19

    Program Actions Taken During the Reporting Period as a Result of OIG Action .......................................... 19

    Agency Legislative and Regulatory Proposals Reviewed ................................................................................. 20

Appendix B. Reports Issued ................................................................................................................................... 21

    Agency Management ......................................................................................................................................... 21

    Credit/Capital Programs ................................................................................................................................... 21
    Disaster Assistance............................................................................................................................................ 21

    Contracting and Counseling Programs............................................................................................................. 21

    Top Management Challenges ............................................................................................................................ 21

Appendix C. Reports, Recommendations, and Management Decisions ............................................................... 23

    Reports with Questioned Costs (dollars) .......................................................................................................... 23
    Reports with Recommendations that Funds Be Put to Better Use ................................................................. 23

    Reports from Prior Periods with Overdue Management Decisions ................................................................. 23
    Reports from Prior Periods with Open Recommendations as of March 31, 2022 (dollars) ........................... 24

    Significant Recommendations from Prior Reporting Periods Without Final Action as of March 31, 2022 ... 25

    Significant Recommendations from this Reporting Period.............................................................................. 31

    Significant Management Decisions with which OIG Disagrees ...................................................................... 40

    Significant Revised Management Decisions ..................................................................................................... 40

    Federal Financial Management Improvement Act .......................................................................................... 40

    Instances of Interference ................................................................................................................................... 40
Appendix D. Investigations Reporting Statistics .................................................................................................. 41




                                                                              Spring 2022 Semiannual Report to Congress | iv
                              U.S. Small Business Administration | Office of Inspector General

    Investigative Reports Issued ............................................................................................................................. 41

    Persons Referred for Prosecution ...................................................................................................................... 41

    Pandemic-Related Investigative Statistics ....................................................................................................... 41

    Whistleblower Retaliation Cases ...................................................................................................................... 41
    Investigations Involving a Senior Government Employee Where Misconduct Was Substantiated .............. 41

    Investigations Involving a Senior Government Employee That Are Closed and Not Disclosed to the Public
    ............................................................................................................................................................................ 41
Appendix E. Legal Actions Summary .................................................................................................................... 42

    Legal Actions, October 1, 2021–March 31, 2022 .............................................................................................. 42

Appendix F. Cosponsored and Other Activities..................................................................................................... 48

Appendix G. External Peer Reviews ...................................................................................................................... 50

Audits Division........................................................................................................................................................ 50

Investigations Division ........................................................................................................................................... 50

Appendix H. Reporting Requirements in the Inspector General Act of 1978, As Amended ............................... 51
Make a Difference ................................................................................................................................................... 52




                                                                                  Spring 2022 Semiannual Report to Congress | v
U.S. Small Business Administration | Office of Inspector General


SBA’s Top Management and Performance
Challenges

Each year, OIG is required to report on the
most serious management challenges facing        SBA Top Management &
the agency.                                      Performance Challenges FY 2022
In accordance with the Reports                   Challenge 1
Consolidation Act of 2000 and Office of          SBA’s Economic Relief Programs Are Susceptible to
Management and Budget (OMB) Circular A-          Significant Fraud Risks and Vulnerabilities
136, SBA includes this information in the        Challenge 2
agency financial report.                         Inaccurate Procurement Data and Eligibility Concerns in
                                                 the Small Business Contracting Programs Undermine the
The management challenges represent areas
                                                 Reliability of Contracting Goal Achievements
that OIG considers particularly vulnerable to
fraud, waste, abuse, or mismanagement, or        Challenge 3
which otherwise pose significant risk to the     SBA Faces Significant Challenges in IT Investment, System
agency, its operations, or its credibility.      Development, and Security Controls
                                                 Challenge 4
Each management challenge generally has
                                                 SBA Risk Management and Oversight Practices Need
originated from one or more reports issued
                                                 Improvement to Ensure the Integrity of Loan Programs
by OIG or the Government Accountability
Office (GAO).                                    Challenge 5
                                                 SBA’s Management and Monitoring of the 8(a) Business
We do not usually rank the top challenges in     Development Program Needs Improvement
order of importance or magnitude, except
                                                 Challenge 6
for the COVID-19 challenge. We view all
                                                 Identification of Improper Payments in SBA’s Loan
eight challenges as critically important to      Programs Remains a Challenge
SBA operations in the upcoming year.
                                                 Challenge 7
However, we placed COVID-19 economic             SBA’s Disaster Assistance Program Must Balance
relief programs at the top of the list for the   Competing Priorities to Deliver Prompt Assistance but
2022 report in recognition that it is the        Prevent Fraud
agency’s most acute challenge.                   Challenge 8
You can find the Top Management and              SBA Needs Robust Grants Management Oversight
Performance Challenges Facing the Small
Business Administration in Fiscal Year 2022 in
the Reports section of the SBA OIG website.




1 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Summary of OIG Oversight Work

Pandemic Response Oversight
To support businesses affected by the Coronavirus Disease 2019 (COVID-19) pandemic, in FY 2021,
Congress tasked SBA with lending $470 billion in COVID-19 Economic Injury Disaster Loans (EIDL) and $20
billion in COVID-19 EIDL Advances. Congress appropriated additional funds for new disaster assistance
programs: $35 billion for Supplemental Targeted Advances, $16.25 billion for the Shuttered Venue
Operators Grant program, and $28.6 billion for the Restaurant Revitalization Fund.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided $349 billion for the creation of
the Paycheck Protection Program (PPP) under Section 7(a) of the Small Business Act. Congress added an
additional $310 billion to the PPP on April 24, 2020, through the Paycheck Protection Program and
Health Care Enhancement Act.
The Consolidated Appropriations Act of 2021, the Economic Aid to Hard-Hit Small Businesses, Nonprofits,
and Venues Act, extended the program through March 31, 2021, providing an additional $147.5 billion in
PPP funding. Lastly, the American Rescue Act provided an additional $7.25 billion, which increased the
total program funding to $813.7 billion.
SBA’s need to quickly provide relief to small businesses led to reduced controls on pandemic-related
loans and grants, substantially increasing the fraud risk. It was immediately clear that pandemic relief
efforts had drawn the attention of unscrupulous and greedy criminals. Complaints from lenders and
allegations of misuse of funds overwhelmed OIG’s Hotline. A growing national narrative told of
widespread fraudulent activity involving funds intended to provide economic relief to qualifying small
businesses and entrepreneurs. We launched investigations and audits to root out the fraud and abuse
endangering these critical resources.
The following summarizes our pandemic oversight work this period.

Audits, Inspections, and Evaluations
                  SBA’s Emergency EIDL Grants to Sole Proprietors and Independent
                  Contractors (Report 22-01)
                 We determined if the agency complied with its internal policy that set emergency EIDL
                 advance grants at $1,000 per employee up to the CARES Act mandated maximum
amount of $10,000. We examined emergency EIDL grants to sole proprietors and independent
contractors from March 29 to July 10, 2020, when the funds were exhausted.
We found the agency provided $4.5 billion more in grants to sole proprietors and independent
contractors than they were entitled to receive based on established policy. We determined that 542,897
sole proprietors applied for the grants without an Employer Identification Number (EIN) and claimed
more than one employee on their applications.




                                                    Spring 2022 Semiannual Report to Congress | 2
U.S. Small Business Administration | Office of Inspector General

The absence of an EIN indicates the sole proprietor applicants should have claimed no employees and
were entitled to a maximum of $543 million ($1,000 per applicant). However, SBA disbursed $4 billion in
Emergency EIDL grant funds to these sole proprietors, an over disbursement of $3.5 billon.
We also found 161,197 independent contractors also applied but did not provide an EIN and claimed
more than one employee on their COVID-19 EIDL application. The independent contractors were entitled
to a maximum of $161 million ($1,000 per applicant). However, SBA disbursed $1.1 billion to the
independent contractors, an over disbursement of about $1 billion.
We recommended SBA remedy $4.5 billion in funds disbursed over its policy allowance. The agency
disagreed with the prior Administration’s policy determination, which was the criteria we used to
premise our findings. Despite management’s disagreement, the agency is taking corrective actions to
implement our recommendation.
Access this Inspection Report on the SBA OIG Reports site.

                   COVID-19 EIDL Program Recipients on the Department of Treasury’s
                   Do Not Pay List (Report 22-06)
                     Our review of the Department of Treasury’s analysis of processed COVID-19 EIDLs and
                     emergency EIDL grants from March to November 2020 revealed that SBA’s lack of
adequate pre-award controls during this period of review led to 75,180 COVID-19 EIDLs, totaling over
$3.1 billion, and 117,135 emergency EIDL grants, totaling over $550 million, being disbursed to
potentially ineligible recipients.
To prevent potential improper payments, we recommended SBA use the batch match or continuous
monitoring functions available in Treasury’s Do Not Pay Do Not Pay portal to identify potentially ineligible
applicants before disbursing COVID-19 EIDL program funds.
SBA managers partly agreed with our recommendations. Starting April 6, 2021, SBA implemented
procedures which included Treasury Do Not Pay monitoring. The agency started using Do Not Pay
functions and data sources for all COVID-19 relief programs to identify potentially ineligible applicants
before disbursing funds.
Access this Management Advisory on the SBA OIG Reports site.

                   SBA’s Oversight of the Grant Recipient’s Implementation of the
                   CARES Act Resource Partners Training Portal (Report 22-07)
                    We evaluated SBA’s handling of the grant to establish a single centralized hub for
                    federal resources available to small businesses in the wake of the COVID-19 pandemic.
SBA awarded $18.6 million for the informational and training hub in the critical first year of the disaster
response. After launch, less than 1 percent of the 30 million small businesses it was intended to help
used it, and only 62 of about 14,000 resource partner counselors and mentors completed any of the
training modules.
We found SBA did not ensure the grant recipient developed and implemented an effective marketing
and outreach strategy to ensure the hub successfully achieved its legislative purpose. In addition, neither
SBA nor the grant recipient set targets for any of the performance goals. We found the grant recipient



3 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General

awarded contracts without assessing the reasonableness of contract costs. We also questioned $14.8
million in costs that either did not adhere to procurement requirements or were not properly supported.
SBA agreed or partially agreed with three of our five recommendations. The agency plans to implement
corrective actions that will align performance goals with agency goals. It will also enhance oversight of
the grant recipient’s compliance with award terms and federal requirements.
Access this Evaluation Report on the SBA OIG Reports site.

                   SBA’s Paycheck Protection Program Loan Review Processes (Report
                   22-09)
                   We found SBA’s online loan forgiveness platform used by lenders to submit PPP
                   forgiveness requests is adequate to support SBA’s loan review process. However, SBA
did not meet the 90-day statutory requirement to remit forgiveness payments to lenders for 98.2
percent of loans over $2 million. Not completing reviews of loans and remitting payment promptly
creates uncertainty for borrowers and PPP lenders who are unsure if SBA will forgive the loans.
We also identified other matters that SBA should address, including how SBA made changes to allow
certain loans to be reviewed for fraud and eligibility after they had been forgiven. These changes could
affect SBA’s ability to recover funds for forgiven loans later determined to be ineligible. Outstanding loan
forgiveness applications are a potential indicator of fraud. Borrowers who fraudulently obtained a PPP
loan are unlikely to apply for loan forgiveness. We identified 1.9 million loans totaling $177.3 billion with
no forgiveness application as of May 2021.
We recommended SBA develop a plan to ensure remaining forgiveness reviews and remittances are
completed within 90 days as required by the CARES Act. SBA management agreed with the report finding
and recommendation.
Access this Evaluation Report on the SBA OIG Reports site.

Notable Investigations
              Members of Los Angeles-Based Fraud Ring Sentenced in Multimillion-
              Dollar Scheme
              Seven members of a Los Angeles-based fraud ring were sentenced in a scheme that
              involved submitting 150 PPP and EIDL applications, obtaining more than $20 million in
              pandemic economic relief funds.
The defendants used dozens of fake, stolen, or synthetic identities, including names belonging to elderly
or deceased people and foreign exchange students. The defendants also submitted false and fictitious
documents to lenders and SBA, including fake identity documents, tax documents, and payroll records.
The defendants then used the funds intended to help struggling small businesses for down payments on
luxury homes in Tarzana, Glendale, and Palm Desert, California. They also used the funds to buy gold
coins, diamonds, jewelry, luxury watches, fine imported furnishings, designer handbags, and a Harley-
Davidson motorcycle. The leader of the fraud ring was sentenced to 17 years in prison. Two others were
sentenced to 6 years and another conspirator to 5 years.



                                                     Spring 2022 Semiannual Report to Congress | 4
U.S. Small Business Administration | Office of Inspector General

              Oakland Woman Sentenced to 3 Years in Million Dollar Pandemic Relief
              Fraud
            A California woman pled guilty to bank fraud and money laundering and received 36
            months in prison. She obtained pandemic relief funds from both the PPP and EIDL for
            multiple fictitious businesses, fraudulently claiming 89 employees and a monthly payroll of
more than $700,000.
The woman admitted receiving $992,291 in PPP loans and $150,900 in EIDLs and advances. She used the
money for a buying spree of high-end luxury items and services, such as $184,000 on private jet travel
and hotel expenses; $124,000 on luxury purchases from Louis Vuitton, Neiman Marcus, and Nordstrom;
and $16,000 on boat and car rentals. She spent another $150,000 on Mercedes-Benz, Land Rover, and
Nissan automobiles. She was also ordered to pay $1.1 million in restitution.

              Texas Man Sentenced to More Than 9 Years in COVID-19 Fraud and
              Money Laundering Scheme
              A Texas man pled guilty to charges of wire fraud and money laundering for fraudulently
              obtaining over $1.6 million in PPP funds. He falsely represented the number of employees
              and payroll expenses in PPP loan applications.
After he received the PPP loan funds, he bought a Lamborghini Urus, a Ford F-350 truck, and a Rolex
watch. The U.S. Department of Justice, along with other law enforcement partners, seized over $700,000
of the funds. This case was investigated by SBA OIG, the Federal Housing Finance Agency Office of
Inspector General, and the U.S. Postal Inspection Service Criminal Investigations.

              California Man Convicted in $27 Million PPP Fraud Scheme
              A California man who submitted 27 PPP fraudulent loan applications seeking $27 million
              was convicted of bank fraud, submitting false statements to a financial institution, and
              money laundering. In his fraudulent applications, he stated that these shell companies had
              100 employees and average monthly payrolls of $400,000.
Evidence showed he also submitted Internal Revenue Service documents falsely stating that each of the
companies had an annual payroll of $4.8 million. He used the $3 million in PPP funds he received for
personal expenses, including renting an oceanfront apartment in Santa Monica.

              Two Florida Men Pled Guilty to $35 Million COVID-19 Relief Fraud
              Scheme
               Two Florida men pled guilty to conspiracy to commit wire fraud in the Northern District of
               Ohio for leading a nationwide scheme to fraudulently obtain over $35 million in PPP loans.
               They recruited additional PPP loan applicants, preparing and submitting fraudulent loan
applications in exchange for a share of the proceeds. They submitted or facilitated at least 79 fraudulent
loan applications worth at least $35 million—and planned to submit more.




5 | Spring 2022 Semiannual Report to Congress
                     U.S. Small Business Administration | Office of Inspector General

               Man Who Evaded Justice Sentenced to Federal Prison for Pandemic
               Relief Fraud
               After fleeing federal prosecution and being re-arrested, a former Oregon man was
               sentenced to about 5 years in federal prison for stealing funds intended to help small
               businesses during the COVID-19 pandemic.
According to court documents, a small business owner contacted the Clackamas County Sheriff’s Office
to report that an unknown person had obtained and used personal information belonging to him, his
wife, and their business to establish accounts at a bank in Boston, Massachusetts. A review of SBA
records revealed that six EIDL applications had been submitted using that small business owner’s social
security number.
Of the six applications, two were funded for a total of $295,000. Investigators traced wire transferred
funds made by the fraudster to the purchase of a Ford F-350 Lariat truck for $77,898 using a counterfeit
California driver’s license. The suspect was later found to have provided business services to the small
business owner whose identity he had stolen.

               Arizona Man Sentenced to 32 Months in Federal Prison for Fraudulent
               EIDL Applications
               An Arizona man was sentenced to 32 months in federal prison for submitting fraudulent
               EIDL applications on behalf of more than 70 limited liability companies. He received $3.8
               million in loans and $336,000 in grants.
In these applications, he made false statements about the number of employees, the amount of gross
revenues, and cost of goods sold. He also falsely agreed to use the funds as working capital and instead
used the economic assistance money to purchase a new home.

               Oregon Dentist Faces Federal Charges for Stealing About $8 Million in
               COVID-Relief Program Funds
               An Oregon man who attempted to defraud the EIDL program of millions and then set his
               sights on the Restaurant Revitalization Fund is facing federal charges for obtaining nearly
               $8 million in funds meant to help small businesses adversely affected by the pandemic.
He submitted three restaurant revitalization applications for restaurants allegedly located in Sarasota,
Miami, and Daytona Beach, Florida. The suspect’s applications contained false business information and
listed his personal residence as the business mailing address.
He had first attempted to steal EIDL funds using the names and Employer Identification Numbers of
fictitious business entities. He further provided false information about the business start dates, number
of employees, locations, and the identities of the purported applicants and business owners.
All of the applications were submitted online from an internet protocol address associated with the
defendant’s dental practice.




                                                    Spring 2022 Semiannual Report to Congress | 6
U.S. Small Business Administration | Office of Inspector General


Small Business Access to Capital
SBA provides small businesses with capital and financial assistance through several key programs. SBA
has a financial assistance portfolio of guaranteed and direct loans that totaled about $453 billion as of
September 30, 2021. Over the years, OIG has worked closely with the agency to identify potential points
of risk and improve SBA’s oversight and controls to ensure eligible participants most in need of assistance
benefit from these programs.
The Section 7(a) Loan Program is SBA’s principal vehicle for providing small businesses with access to
credit that cannot be obtained elsewhere. Proceeds from a 7(a) loan may be used to establish a new
business or to assist in acquiring, operating, or expanding an existing business. This program relies on
numerous outside parties (such as borrowers, loan agents, and lenders) to complete loan transactions.
SBA has centralized several loan approval and servicing functions and reduced the number of staff
performing these functions, placing more responsibility on and giving greater independence to lenders.
Past OIG reviews have reported on these trends, and OIG continues to identify weaknesses in SBA’s
lender and loan agent oversight processes.
Criminals use a wide array of techniques to fraudulently get—or induce others to obtain—SBA-
guaranteed loans. The techniques include submitting fraudulent documents, making fictitious asset
claims, manipulating listed property values, using loan proceeds contrary to the terms of the loans, and
failing to disclose debts or previous criminal records.
Consequently, there is a greater chance of financial loss to the agency and its lenders. OIG dedicates a
significant portion of its resources to identifying wrongdoers and, whenever possible, recovering taxpayer
funds.
During this semiannual period, our audit work in this program area was focused on the pandemic
response programs. We have included those reports in the Pandemic Response Oversight section.

Investigations
              Jury Convicts Five Former Officers and Employees of Banc-Serv Partners
              in $5 Million Scheme
              Five former officers and employees of Banc-Serv Partners LLP, a lending service provider,
              were convicted in a 13-year conspiracy to defraud the SBA loan guarantee program of $5
              million in guaranteed disbursements.
The defendants, including a former president and company founders, fraudulently obtained SBA-
guaranteed loans on behalf of their clients, knowing that the loans did not meet SBA’s guidelines and
requirements for the guarantees.
Evidence proved that from 2004 until 2017, the defendants helped originate SBA loans on behalf of
various financial institutions and other lenders and, on multiple occasions, fraudulently obtained
guarantees for loans that SBA had deemed ineligible.
They knowingly misrepresented what the loans would be used for and unlawfully diverted previously
denied loan applications into expedited approval channels at SBA. When the fraudulently guaranteed
loans defaulted, the defendants caused the submission of the reimbursement requests to SBA to


7 | Spring 2022 Semiannual Report to Congress
                     U.S. Small Business Administration | Office of Inspector General

purchase the defaulted loans from investors and lending institutions, shifting some of the losses on the
ineligible loans to SBA.
The defendants face a maximum sentence of 30 years in prison per count. The charge of conspiracy to
commit wire fraud carries a maximum sentence of 20 years.




                                                   Spring 2022 Semiannual Report to Congress | 8
U.S. Small Business Administration | Office of Inspector General


Disaster Assistance Program
Disaster assistance has been part of the agency since its inception in 1953. SBA provides long-term, low-
interest financial assistance to businesses of all sizes, private nonprofits, homeowners, and renters
following a declared disaster. Each year, SBA approves hundreds of millions of dollars in disaster
assistance loans.
The disaster assistance loan program is the only form of SBA assistance not limited to small businesses.
The program’s disaster assistance loans are the primary form of federal assistance for repairing and
rebuilding nonfarm, private sector losses following a declared disaster.
The program includes four categories of loans for disaster-related losses:
            •   Home disaster loans
            •   Business disaster loans (includes PPP loans)
            •   Economic injury disaster loans (includes pandemic relief loans)
            •   Military reservist economic injury loans
During this semiannual period, our audit and investigations work in this program area was focused on the
pandemic response programs. We have included those reports and investigations in the Pandemic
Response Oversight section.




9 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Contracting and Counseling Programs
The U.S. government is the largest single purchaser of goods and services in the world, awarding over
$550 billion in prime contracts annually. SBA works to maximize opportunities for small businesses to
receive these contract awards. As mandated by the Small Business Act, the government-wide goal is to
award at least 23 percent of contract dollars to small businesses.
SBA has specific programs that focus on strengthening particular types of small businesses, like those
owned by service-disabled veterans and women, as well as small businesses that are disadvantaged or
located in historically underutilized business zones (HUBZones).
The HUBZone program helps small businesses stimulate their economically challenged local economies.
Similarly, to help small, disadvantaged businesses gain access to federal and private procurement
markets, SBA’s 8(a) Business Development Program helps small businesses owned by socially and
economically disadvantaged individuals gain business skills and access to federal contracting
opportunities so that they can better compete in the open marketplace. The program offers free
business development education, training workshops, and match-making opportunities with federal
buyers.
SBA also aids existing and prospective small businesses through a variety of counseling and training
services offered by partner organizations. Among these partners are Small Business Development
Centers, the SCORE mentoring network, Women’s Business Centers, and Veterans Business Outreach
Centers. SBA also started the Community Navigator Pilot Program, an American Rescue Plan initiative.
The program will provide funding to organizations that will work with local community groups to improve
access to SBA and government resources.
Additionally, SBA designed the Boots to Business program, providing transitioning service members
interested in exploring business ownership or other self-employment opportunities with technical
assistance and access to resources. These programs require effective and efficient management,
outreach, and service delivery.

Audits, Inspections, and Evaluations
                   SBA’s Business Development Assistance to 8(a) Program Participants
                   (Report 22-08)
                 We reviewed the business development assistance SBA provided 8(a) program
                 participants from 2011-20, reviewing the files for 40 of the firms. We also examined
whether the program adapted successfully during the pandemic.
We found that 15 of the 40 firms we reviewed did not have approved business plans, making these firms
ineligible to receive $93 million in 8(a) awards. We also found SBA did not consistently document that its
staff assessed the needs, counseled, or conducted field visits with 8(a) firms to ensure they received the
assistance needed to be prepared to compete for contracts without long-term 8(a) assistance.
However, we found SBA program officials offered program flexibilities to all 8(a) participants during the
pandemic, adapting business development assistance to help firms stay in business and remain in the




                                                  Spring 2022 Semiannual Report to Congress | 10
U.S. Small Business Administration | Office of Inspector General

program. We made eight recommendations for the agency to measure, monitor, and better deliver
training and other business development assistance to 8(a) firms.
SBA management agreed with most of our recommendations. SBA plans to identify program-level goals
that align with the agency’s strategic plan. SBA also plans to assess the staffing and resources allocated
for SBA district offices to consistently provide business development assistance and improve program
participants’ customer experience.
Access this Audit Report on the SBA OIG Reports site.

Investigations
              Former Construction Company Owner Indicted for Defrauding Federal
              Program Intended for Service-Disabled Veteran-Owned Small Businesses
               The former owner of several construction companies, along with two co-conspirators,
               were charged with conspiracy to defraud the United States in a long-running scheme to
obtain valuable government contracts under an SBA certification program. The two co-conspirators pled
guilty to the scheme in November 2020 and March 2021.
As part of the scheme, one of the defendants installed a service-disabled veteran as the ostensible owner
of a general construction company. The business was then purported to be eligible for contracts set aside
for Service-Disabled Veteran-Owned Small Businesses. The suspects ineligible for the veteran certification
exercised financial and operational control over the company.
According to court documents, the conspirators concealed control of the business to secure over $250
million in government contracts as early as 2004, continuing through to at least 2017. The fraud
prevented qualifying service-disabled veteran businesses from securing these lucrative government
contracts.
For conspiracy to commit wire fraud and to defraud the United States, the defendant faces a maximum
penalty of 5 years in prison and a $250,000 fine. For each wire fraud count, the defendant faces a
maximum penalty of 20 years in prison and a $250,000 fine.




11 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Agency Management
OIG is responsible for ensuring that agency management appropriately safeguards SBA from fraud,
waste, and abuse, and that SBA activities directly further agency goals. As part of this work, OIG
coordinates with the offices of the Chief Financial Officer, the Chief Information Officer, and the Chief
Operating Officer to review financial reporting and performance management, human resources,
procurements and grants, space and facilities, and maintenance of SBA’s information systems and
related security controls.

Audits, Inspections, and Evaluations
                   SBA’s Controls Over Cash Contributions and Gifts, Fiscal Years 2021
                   and 2020 (Report 22-03)
                    We are responsible for semiannual audits to determine the adequacy of SBA controls
                    over the solicitation, acceptance, holding, and use of cash contributions and gifts and
ensuring the agency is appropriately using and accounting for such gifts. The Consolidated Appropriations
Act in 2021 and 2020 granted SBA the authority to accept gifts of up to $4 million. In addition, SBA must
put any cash gifts into a separate account.
The only activity for this review period relates to cash contributions for 2020 National Small Business
Week. We found SBA complied with the Consolidated Appropriations Act and SBA regulations and
policies regarding soliciting and accepting cash contributions. The 10 entities that cosponsored the
business week were properly vetted through SBA program offices to ensure no business relationship
existed that would cause a conflict of interest. They provided cash contributions totaling $360,000.
Although SBA adequately complied with applicable laws and policies, we noted control deficiencies in the
close out of the event. We made recommendations to ensure all cosponsored activities are closed out in
a timely manner in accordance with SBA standard operating procedures. SBA management agreed with
our recommendations and proposed to clarify language in the National Small Business Week
cosponsorship and joinder agreements to emphasize the 90-day close out requirement. Management
also assigned staff to perform monthly reconciliations to ensure the fiscal agent reporting is accurate.
Access this Compliance Report on the SBA OIG Reports site.

                  Independent Auditors’ Report on SBA’s Compliance with DATA Act
                  Reporting (Report 22-04)
                  The Digital Accountability and Transparency (DATA) Act of 2014 requires OIG to
                  annually audit SBA’s financial data and adherence to government financial data
standards. We contracted with the independent certified public accounting firm KPMG LLP to conduct
the annual audit.
KPMG’s audit provided findings on the agency’s reporting required under the DATA Act. SBA met the
government-wide financial data standards, and the data submission was of higher quality than in
previous years. The agency has made progress since the 2019 audit increasing the availability, accuracy,
and usefulness of federal spending information.



                                                   Spring 2022 Semiannual Report to Congress | 12
U.S. Small Business Administration | Office of Inspector General

However, SBA did not submit certain data completely, accurately, or on time. In addition, SBA needs to
improve the completeness and accuracy of DATA Act reporting.
Access this Audit Report on the SBA OIG Reports site.

                  Independent Auditors’ Report on SBA’s FY 2021 Financial Statements
                  (Report 22-05)
                  The Chief Financial Officers Act of 1990, as amended, requires an annual independent
                  audit and report on SBA’s consolidated financial statements. We contracted with the
independent certified public accounting firm KPMG LLP to conduct an audit of SBA’s consolidated
balance sheets for Fiscal Years 21 and 20 and the notes related to those statements. KPMG was also
engaged to audit the consolidated statements of net cost and changes in net position and combined
statement of budgetary resources for FY 2020.
KPMG auditors found significant matters for which they were unable to obtain sufficient and appropriate
audit evidence to provide a basis for an audit opinion on SBA’s consolidated financial statements for FY
2021. KPMG issued a disclaimer of opinion on the consolidated financial statements for FYs 21 and 20.
Because of 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 the expanded Paycheck
Protection and Economic Injury Disaster Loan programs and the newly implemented Restaurant
Revitalization Fund and Shuttered Venue Operators Grant program.
For FY 2021, KPMG identified six material weaknesses and two significant deficiencies in internal controls
over financial reporting. We provided a draft of KPMG’s audit report to SBA’s Acting Chief Financial
Officer, who did not concur with the severity of five material weaknesses.
Access this Audit Report on the SBA OIG Reports site.




13 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Other Significant OIG Activities
Background Investigations Ensure Integrity
During this reporting period, OIG initiated 63 background investigations and issued two security
clearances for OIG employees and contractors. OIG adjudicated 16 background investigative reports.

Debarment and Other Administrative Enforcement Actions
OIG promotes program integrity by making present responsibility referrals to SBA and other agencies.
Present responsibility means the business ethics, integrity, honesty, and competence of persons who
participate in SBA programs or otherwise do business with the government. During this reporting period,
OIG sent 43 present responsibility referrals to SBA.
Present responsibility referrals can result in suspensions, debarments, and similar administrative
enforcement actions. These actions protect taxpayer funds from program participants who are not a
good risk for the government.
A typical OIG referral contains a summary of allegations and criminal, civil, administrative, or other
evidence supporting the recommendation. Most OIG administrative referrals involve SBA’s loan and
contract programs. OIG ensures that a suspension and debarment official reviews all appropriate
allegations arising in other contexts, such as the investigation of False Claims Act cases.

Stakeholder Presentations on PPP and EIDL Fraud
During this reporting period, SBA OIG held 97 presentations for internal and external stakeholders to
raise awareness of fraud, waste, and abuse related to SBA programs. More than 3,500 participants
attended these events.

Reviews of Proposed Agency Regulations, Operating Procedures, and
Other Initiatives Lead to Improved Program Controls
OIG reviews changes SBA proposes to make to its program directives, such as regulations, internal
operating procedures, agency policy notices, and SBA forms completed by the public. OIG often identifies
material weaknesses in the proposals and works with the agency to promote more effective controls to
deter waste, fraud, and abuse. During the reporting period, OIG reviewed 81 proposed revisions of these
program directives and submitted comments designed to improve eight of the initiatives.

Approval of Small Business Development Center Surveys
Section 21(a)(7) of the Small Business Act states that until Small Business Development Center
information disclosure regulations are issued, the Inspector General must approve any related client
survey, as well as the use of any survey information. OIG must also include this approval in the
semiannual report. SBA did not submit any surveys OIG review during this reporting period.




                                                  Spring 2022 Semiannual Report to Congress | 14
U.S. Small Business Administration | Office of Inspector General


OIG Hotline
OIGs have a Hotline function that takes complaints from anyone who
suspects waste, fraud, abuse, or serious mismanagement within an
agency or its programs by employees, contractors, and the public.
Hotline complaints may result in corrective actions, audits, or
administrative, civil, or criminal investigations.
Our Hotline staff vets complaints and monitors the progress of
matters referred to SBA program offices for action to ensure the
agency has promptly followed up, adequately resolved allegations,
and documented any corrective actions.

Significant Increases
Hotline work has changed dramatically because of the COVID-19 pandemic. OIG’s Hotline team has been
diligently working through a large backlog of complaints. The staff is addressing each complaint received
via online submissions to the SBA OIG website, telephone, e-mail, and posted mail, as well as referrals
                                              from banks and other agencies.
                                            The number of complaints has increased by orders of
                                            magnitude since the COVID-19 pandemic relief programs
                                            were established by Congress, which has overwhelmed the
                                            system and our staff.
                                            During this semiannual period, the OIG Hotline received
                                            more than 33,600 complaints of loan fraud and abuse,
                                            identity theft, and problems with SBA’s customer service.
                                            In total, since the pandemic began in March 2020, OIG has
                                            received more than 200,000 complaints. By contrast, the
                                            OIG Hotline received 742 complaints in calendar year 2019.




15 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Organizational Overview
U.S. Small Business Administration
The mission of the SBA under the Small Business Act, as amended, is to maintain and strengthen the
nation’s economy by enabling the establishment and vitality of small businesses and assisting in the
economic recovery of communities after disasters. The agency’s strategic plan for FYs 2022-26 has three
key goals:
    1. Ensure equitable and customer-centric design and delivery of programs to support small
       businesses and innovative startups
    2. Build resilient businesses and a sustainable economy
    3. Implement strong stewardship of resources for greater impact
SBA is organized around the areas of financial, contracting, entrepreneurial development, and disaster
assistance. The agency also represents small businesses through an independent advocate and an
ombudsman.
SBA headquarters is in Washington, D.C. The agency has staff in 10 regional offices, 68 district offices and
corresponding branch offices, and 4 disaster field offices. SBA also has 6 government contracting area
offices and maintains a network of resource partners in all 50 states, the District of Columbia, Puerto
Rico, American Samoa, the U.S. Virgin Islands, and Guam.

Office of Inspector General
                                                                   OIG’s mission is to provide
                                                                   independent, objective, and timely
                                                                   oversight to improve the integrity,
                                                                   accountability, and performance of SBA
                                                                   and its programs for the benefit of all
                                                                   Americans.
                                                                   Our strategic plan for FYs 2022-27 has
                                                                   four goals. In addition to the Office of
                                                                   Counsel to the Inspector General, three
                                                                   divisions assist in carrying out the
                                                                   statutory responsibilities of the OIG:
                                                                   the Audits Division, Investigations
                                                                   Division, and the Management and
                                                                   Operations Division.
                                                                   Our vision is to be valued and engaged
                                                                   change agents who set the standard for
                                                                   oversight excellence in support of
                                                                   America’s small businesses.




                                                   Spring 2022 Semiannual Report to Congress | 16
U.S. Small Business Administration | Office of Inspector General

We seek to demonstrate our values of integrity, commitment, and excellence as we deliver products and
services of the highest quality defined by accuracy, timeliness, fairness, and usefulness.
The Office of Counsel provides legal and ethics advice to all OIG components; protects the OIG’s interests
in litigation arising out of or affecting OIG operations; assists with the prosecution of criminal, civil, and
administrative enforcement matters; processes subpoenas; responds to Freedom of Information and
Privacy Act requests, and reviews and comments on proposed policies, regulations, legislation, and
procedures.
The Audits Division performs and oversees audits and reviews to promote the economical, efficient, and
effective administration of SBA programs and operations. Key areas of emphasis are SBA loan, disaster
assistance, business development, and government contracting programs, as well as mandatory and
other statutory audit requirements involving information technology security, financial reporting, and
other SBA program areas. The balance of the engagements is discretionary and focuses on high-risk
activities and identified management issues.
The Investigations Division manages a program to detect and deter illegal and improper activities
involving SBA’s programs, operations, and personnel. The criminal investigations staff carries out a full
range of traditional law enforcement functions. Within the division, the Hotline reviews allegations of
waste, fraud, abuse, and severe mismanagement within SBA or its programs made by employees,
contractors, and the public.
A preliminary review of all complaints is conducted to determine the appropriate course of action. As
part of the review process, Hotline staff may coordinate reviews of allegations within OIG, SBA program
offices, or other government agencies. The Security Operations Staff within the division conducts
required employee and contractor background investigations to achieve a high level of integrity in the
agency's workforce. It makes adjudications on OIG employees and contractors for issuance of PIV cards
pursuant to HSPD-12 background investigations requirements.
The Management and Operations Division provides business support (e. g., budget and financial
management, human resources, IT, data analytics, and procurement) for various OIG functions and
activities.
OIG’s headquarters is in Washington, D.C. Our field offices are in Atlanta, Georgia; Chicago, Illinois; Dallas-
Fort Worth, Texas; Detroit, Michigan; Denver, Colorado; Herndon, Virginia; Houston, Texas; Los Angeles,
California; Miami, Florida; New York, New York; Philadelphia, Pennsylvania; Federal Way, Washington;
and Washington, D.C.




17 | Spring 2022 Semiannual Report to Congress
U.S. Small Business Administration | Office of Inspector General




                     Spring 2022 Semiannual Report to Congress | 18
U.S. Small Business Administration | Office of Inspector General


Appendixes
Appendix A. Reporting Period Statistical Highlights
Summary of OIG Dollar Accomplishments (dollars)
   Dollar Accomplishments as a Result of Investigations and Related Activities              —
   Potential Investigative Recoveries and Fines                                             $95,247,267
   Other Recoveries (e.g., administrative seizures with partner law enforcement agencies)   44,965,881
   Asset Forfeitures Attributed to OIG Investigations                                       23,766,105
   Loans/Contracts Not Approved or Canceled as a Result of Investigations                   6,151,506
   Investigations Subtotal                                                                  170,130,759
   Dollar Accomplishments as a Result of Audit Activities                                   —
   Disallowed Costs Agreed to by Management                                                 4,462,481,000
   Recommendations that Funds Be Put to Better Use Agreed to by Management                  0
   Audit Subtotal                                                                           4,462,481,000
   Total OIG Dollar Accomplishments                                                         $4,632,611,759

Efficiency and Effectiveness Activities Related to Audit, Other Reports, and Follow-
up Activities
   Reports Issued                                                                            9
   Recommendations Issued                                                                    70
   Dollar Value of Costs Questioned                                                          $4,607,909,066
   Dollar Value of Recommendations that Funds Be Put to Better Use                           0
   Recommendations with Management Decisions                                                 65
   Recommendations without a Management Decision                                             20
   Collections as a Result of Questioned Costs                                               0

Indictments, Convictions, and Case Actions
   Indictments from OIG Cases                                                                98
   Convictions from OIG Cases                                                                85
   Cases Opened                                                                              334
   Cases Closed                                                                              156


SBA Personnel Actions Taken as a Result of Investigation
   Dismissals                                                                                0
   Resignations and Retirements                                                              0
   Suspensions                                                                               0
   Reprimands                                                                                0

Program Actions Taken During the Reporting Period as a Result of OIG Action
   Present Responsibility Referrals to the Agency                                            43
   Pending at the Agency as of March 31, 2022                                                41
   Suspensions Issued by the Agency                                                          0
   Proposed Debarments Issued by the Agency                                                  0
   Final Debarments Issued by the Agency                                                     0
   Proposed Debarments Declined by the Agency                                                0
   Administrative Agreements Entered by the Agency in Lieu of Debarment                      0
   Present Responsibility Actions by Other Agencies                                          0




19 | Spring 2022 Semiannual Report to Congress
                       U.S. Small Business Administration | Office of Inspector General

Agency Legislative and Regulatory Proposals Reviewed
   Legislation, Regulations, Standard Operating Procedures, and Other Issuances Reviewed              81
   Comments Provided by OIG to Improve Legislation, Regulations, Standard Operating Procedures, and
   Other Issuances                                                                                    8




                                                         Spring 2022 Semiannual Report to Congress | 20
U.S. Small Business Administration | Office of Inspector General

Appendix B. Reports Issued
Agency Management
  Title                                                     Report          Issue Date    Questioned        Funds for
                                                            Number                        Costs             Better Use
                                                                                          (dollars)         (dollars)
  SBA’s Controls Over Cash Contribution and Gifts FY 2021   22-03           10/28/2021    —                 —
  and 2022
  Independent Auditors’ Report on SBA’s Compliance with     22-04           11/8/2021     —                 —
  DATA Act Reporting
  Independent Auditors’ Report on SBA’s FY 2021             22-05           11/15/2021    —                 —
  Financial Statements
  COVID-19 EIDL Program Recipients on the Department        22-06           11/30/2021    —                 —
  of Treasury’s Do Not Pay List
  Program Subtotal                                          4               —             $14,762,774       —

Credit/Capital Programs
  Title                                                     Report          Issue Date    Questioned        Funds for
                                                            Number                        Costs             Better Use
                                                                                          (dollars)         (dollars)
  SBA’s Paycheck Protection Program Loan Review             22-09           2/28/2022     —                 —
  Processes
  Program Subtotal                                          1               —             —                 —

Disaster Assistance
  Title                                                     Report Number    Issue Date   Questioned            Funds
                                                                                          Costs (dollars)       for
                                                                                                                Better
                                                                                                                Use
                                                                                                                (dollars)
  SBA Emergency EIDL Grants to Sole Proprietors and         22-01            10/7/2021    4,500,000,000         —
  Independent Contractors
  Program Subtotal                                          1                —            $4,500,000,000        —

Contracting and Counseling Programs
  Title                                                     Report Number    Issue Date   Questioned            Funds
                                                                                          Costs (dollars)       for
                                                                                                                Better
                                                                                                                Use
                                                                                                                (dollars)
  SBA’s Oversight of the Grant Recipient’s Implementation   22-07            1/18/2022    $14,762,774           —
  of the CARES Act Resource Partners Training Portal
  SBA’s Business Development Assistance to 8(a) Program     22-08            2/14/2022    93,146,292            —
  Participants
  Program Subtotal                                          2                —            $107,909,066          —

Top Management Challenges
  Title                                                     Report Number   Issue Date    Questioned         Funds for
                                                                                          Costs (dollars)    Better Use
                                                                                                             (dollars)
  Top Management and Performance Challenges Facing          22-02           10/15/2021    —                  —
  the Small Business Administration in FY 2022



21 | Spring 2022 Semiannual Report to Congress
                   U.S. Small Business Administration | Office of Inspector General

Program Subtotal                         1                      —           —




                                        Spring 2022 Semiannual Report to Congress | 22
U.S. Small Business Administration | Office of Inspector General


Appendix C. Reports, Recommendations, and Management Decisions
Reports with Questioned Costs (dollars)
    IG Act Reporting Requirement           Reports      Recommendations*          Questioned Costs**   Unsupported
                                                                                  (dollars)            Costs***
                                                                                                       (dollars)
    No management decision made by         1            1                     $10,800,476              10,800,476
    September 30, 2021
    Issued during this reporting period    3            5                     4,607,909,066           4,500,000,000
    Management decisions made during 2                  2                     4,514,262,774           4,500,000,000
    this reporting period
    (i) Disallowed costs                   1            1                     4,462,481,000           4,462,481,000
    (ii) Costs not disallowed              2            2                     51,781,774              37,519,000
    No management decision made by         2            4                     $104,446,768            10,800,476
    March 31, 2022
*Reports may have more than one recommendation.
**Questioned costs are costs found to be improper.
***Unsupported costs may be proper but lack documentation. Unsupported costs are a subset of questioned costs.

Reports with Recommendations that Funds Be Put to Better Use
    IG Act Reporting Requirement          Reports      Recommendations        Recommended Funds for Better Use
                                                                              (dollars)
    No management decision made by        —            —                      —
    September 30, 2021
    Issued during this reporting period   —            —                      —
    Subtotal                              —            —                      —
    Management decisions made             —            —                      —
    during this reporting period
    (i) Recommendations agreed to by      —            —                      —
    SBA management
    (ii) Recommendations not agreed       —            —                      —
    to by SBA management
    No management decision made by        —            —                      —
    March 31, 2022

Reports from Prior Periods with Overdue Management Decisions
    Report     Report Title               Issue Date   Recommendation                   Reason for Delay     Timetable
    Number                                                                                                   for
                                                                                                             Resolution
    21-08      SBA’s Use of Vendors       2/3/2021     Ratify the over $10.8 million    SBA disagreed that   4/30/2022
               Without a Contract                      in payments in accordance        ratification of
                                                       with the FAR and 48 C.F.R. §     unauthorized
                                                       1.602-3.                         commitments was
                                                                                        necessary.




23 | Spring 2022 Semiannual Report to Congress
                   U.S. Small Business Administration | Office of Inspector General

Reports from Prior Periods with Open Recommendations as of
March 31, 2022 (dollars)
 Report   Title                                             Date Issued   Number of Open    Aggregate
 Number                                                                   Recommendations   Potential Cost
                                                                                            Savings (dollars)
 17-19    Audit of SBA’s Microloan Program                  9/28/2017     2                 $137,199.806
 18-03    Independent Auditor’s Report on the SBA’s FY      11/14/2017    1                 —
          2017 Financial Statements
 18-13    Evaluation of SBA 7(a) Loans Made to Poultry      3/6/2018      1                 —
          Farmers
 19-08    SBA’s HUBZone Certification Process               3/28/2019     1                 —
 19-15    OIG High Risk 7(a) Loan Review Program            7/10/2019     1                 3,000,297
 19-16    Office of Inspector General High Risk 7(a) Loan   8/14/2019     2                 2,059,132
          Review Program
 19-17    Evaluation of SBA’s All Small Mentor-Protege      9/17/2019     2                 —
          Program
 20-03    Audit of SBA's Oversight of High-Risk Lenders     11/12/2019    5                 13,313,560
 20-08    Audit of the SBA's Community Advantage Pilot      3/18/2020     6                 51,472,944
          Program
 20-18    Office of Inspector General High Risk 7(a) Loan   8/25/2020     1                 2,094,574
          Review Program
 20-20    Audit of SBA’s Compliance with the Debt           9/30/2020     10                —
          Collection Improvement Act, as Amended
 Total    --                                                --            69                $209,926,274




                                                       Spring 2022 Semiannual Report to Congress | 24
U.S. Small Business Administration | Office of Inspector General

Significant Recommendations from Prior Reporting Periods Without Final Action as
of March 31, 2022
Report     Date Issued     Recommendation                                      Date of      Final Action
Number                                                                         Management   Target Date
                                                                               Decision
17-19      9/28/2017       Continue efforts to improve the information         1/4/2018     12/31/2021
                           system to include outcome-based performance
                           measurements and ensure the data captured
                           can be used to effectively monitor the Microloan
                           Program compliance, performance, and
                           integrity.
17-19      9/28/2017       Update the microloan reporting system manual        1/4/2018     12/31/2021
                           to reflect current technology capabilities.
18-03      11/14/2017      Monitor and perform procedures over the             1/10/2018    9/30/2021
                           service organization’s attestation report
                           regarding user control considerations. This
                           assessment should be performed annually.
18-13      3/6/2018        Review the arrangements between integrators         3/1/2018     9/15/2022
                           and growers under the revised regulations, and
                           establish and implement controls, such as
                           supplemental guidance, to ensure SBA loan
                           specialists and lenders make appropriate
                           affiliation determinations.
19-08      3/28/2019       Implement a plan to mitigate IT issues affecting    3/29/2019    1/31/2022
                           the HUBZone certification process.
19-15      7/10/2019       Require the lender to bring the loan into           7/11/2019    12/1/2021
                           compliance or, if not possible, seek recovery of
                           $3,000,297 plus interest on the guaranty paid by
                           SBA.
19-16      8/14/2019       Require the lender to bring the loan into           8/15/2019    12/1/2021
                           compliance or, if not possible, seek recovery of
                           $1,367,417 plus interest on the guaranty paid by
                           SBA.
19-16      8/14/2019       Require the lender to bring the loan into           8/15/2019    12/1/2021
                           compliance or, if not possible, seek recovery of
                           $691,715 plus interest on the guaranty paid by
                           SBA.
19-17      9/17/2019       Prioritize staff resources to ensure application    2/4/2020     9/30/2022
                           reviews and annual evaluations are conducted in
                           accordance with regulatory and program
                           requirements.
19-17      9/17/2019       Ensure that certify.SBA.gov has the functionality   9/17/2019    9/30/2022
                           needed for program officials to conduct
                           application reviews and annual evaluations.
20-03      11/12/2019      Develop and implement policies and procedures       11/15/2019   7/31/2022
                           to document justification for not conducting
                           planned reviews and identifying and prioritizing
                           additional lenders for review.
20-03      11/12/2019      Develop and implement a comprehensive               11/15/2019   9/30/2022
                           database to manage oversight of high-risk
                           lenders to ensure performance of all planned
                           reviews, implementation of risk mitigation
                           actions, and identification of noncompliant
                           lender and systemic material loan deficiencies.




25 | Spring 2022 Semiannual Report to Congress
               U.S. Small Business Administration | Office of Inspector General

20-03   11/12/2019     Conduct periodic overall assessments of the           11/15/2019   12/31/2021
                       high-risk lender review results and
                       recommended risk mitigation actions to ensure
                       analysts recommend appropriate and consistent
                       corrective and enforcement actions.
20-03   11/12/2019     Develop and implement policies and procedures         11/15/2019   7/31/2022
                       to communicate systemic lender issues and
                       material loan deficiencies to the appropriate SBA
                       loan approval and purchase centers to facilitate
                       proactive portfolio management and to mitigate
                       the risk of improper guaranty purchases in the
                       event of default.
20-03   11/12/2019     Determine whether the lenders corrected the           11/15/2019   4/30/2022
                       deficiencies on the 21 loans purchased for a
                       total of $13.3 million. If not, require the lenders
                       to bring the loans into compliance or, if not
                       possible, seek recovery of the guaranty paid by
                       SBA from lenders.
20-08   3/18/2020      Evaluate options that facilitate the Community        6/30/2020    3/31/2022
                       Advantage pilot program’s ability to effectively
                       expand access to capital in underserved markets.
20-08   3/18/2020      Evaluate whether it is feasible to align the          6/30/2020    3/31/2022
                       maximum interest rates charged under the
                       Community Advantage pilot program with
                       comparable 7(a) program rates, excluding SBA
                       Express.
20-08   3/18/2020      Provide criteria to lenders to assist them with       8/5/2020     12/31/2021
                       assessing the borrowers’ management and
                       technical assistance needs.
20-08   3/18/2020      Establish methods to assess whether lenders           6/30/2020    3/31/2022
                       have the expertise needed to provide
                       management and technical assistance to
                       underserved borrowers and to address any
                       lender deficiencies.
20-08   3/18/2020      Require lenders to complete the data fields           6/30/2020    3/31/2022
                       related to the management and technical
                       assistance provided and enhance the annual
                       Community Advantage performance analysis by
                       including the evaluation of the performance
                       associated with the various types of
                       management and technical assistance.
20-08   3/18/2020      Establish a process to periodically assess the        6/30/2020    12/31/2021
                       performance of Community Advantage loans
                       approved with Small Business Scoring Service
                       scores under 140 to determine whether the
                       recently implemented SBA approval requirement
                       is adequately mitigating the risk of loss.
20-18   8/25/2020      Require the lender to bring the loan into             8/25/2020    12/1/2021
                       compliance or, if not possible, seek recovery of
                       $2,094,574 on the guaranty paid by SBA.




                                             Spring 2022 Semiannual Report to Congress | 26
U.S. Small Business Administration | Office of Inspector General

20-20      9/30/2020       Review all loans assigned to the resolution           9/16/2020   4/29/2022
                           center that are 180 days or more delinquent and
                           classified with code 66 (Lien or Mortgage/Refer
                           to Treasury Offset Program Only) and 00 (Clear
                           Existing Status Code) and transfer the loans to
                           Treasury Cross-Servicing, unless verified as
                           exempt when the temporary suspension of debt
                           collection activities because of the pandemic is
                           lifted.
20-20      9/30/2020       Perform a cost benefit analysis to determine if       9/16/2020   4/29/2022
                           SBA should begin assessing fees to offset the
                           cost of processing and handling delinquent
                           disaster loans.
20-20      9/30/2020       Revise SOP 50 52 to clearly communicate that all      9/16/2020   4/29/2022
                           loans with collateral must be evaluated for
                           foreclosure and placed in foreclosure status
                           before they are 180 days delinquent.
20-20      9/30/2020       Revise SOP 50 52 2 to clearly communicate that        9/16/2020   4/29/2022
                           all debts 180 days delinquent must be
                           transferred to Treasury Cross-Servicing unless
                           the debt meets a valid transfer exemption.
20-20      9/30/2020       Establish requirements to provide annual              9/16/2020   4/29/2022
                           training on Debt Collection Improvement Act
                           requirements to all staff of the resolution center.
20-20      9/30/2020       Ensure that information used to monitor               9/16/2020   4/29/2022
                           compliance with the Debt Collection
                           Improvement Act includes all loans assigned to
                           the resolution center as identified in the Capital
                           Access Financial System.
20-20      9/30/2020       Review all loans currently assigned to the Center     9/16/2020   4/29/2022
                           and designated exempt from Treasury Offset
                           Program and verify that each of the obligors is
                           exempt from referral to Treasury Offset
                           Program, and if not, refer the obligors to
                           Treasury Offset Program as required.
20-20      9/30/2020       Review all loans currently assigned to the Center     9/16/2020   4/29/2022
                           and designated as exempt from Treasury Cross-
                           Servicing that are 180 days or more delinquent
                           and verify that each of the obligors is exempt
                           from transfer to Treasury Cross-Servicing, and if
                           not, transfer the debt to Treasury Cross-
                           Servicing, as required when the temporary
                           suspension of debt collection activities due to
                           COVID-19 is lifted.
20-20      9/30/2020       Establish policies and procedures to require          9/16/2020   4/29/2022
                           routine follow-up on delinquent loans to ensure
                           full compliance with the Debt Collection
                           Improvement Act.
20-20      9/30/2020       Reiterate the requirements for workout                9/16/2020   4/29/2022
                           agreements to responsible personnel to ensure
                           compliance with the Debt Collection
                           Improvement Act.
21-02      10/28/2020      Review all loans that had a bank account number       12/8/2020   3/25/2022
                           changed from that shown on the original
                           application to determine if the changes were
                           legitimate or fraudulent. If not legitimate, work
                           to recover the funds, deobligate any
                           undisbursed funds, and refer to the OIG.



27 | Spring 2022 Semiannual Report to Congress
               U.S. Small Business Administration | Office of Inspector General

21-02   10/28/2020     Review duplicate loans to IP addresses, email        12/8/2020   3/25/2022
                       addresses, business addresses, and bank
                       accounts to determine if there are undisbursed
                       funds that should be suspended until the
                       duplicate loans are assessed for eligibility.
21-02   10/28/2020     Strengthen or establish controls to ensure           8/10/2021   3/25/2022
                       multiple loans are provided only to eligible
                       applicants and prevent the erroneous
                       duplication of loans.
21-02   10/28/2020     Strengthen data integrity to make it possible to     8/10/2021   3/25/2022
                       determine if the inaccurate information allowed
                       loans to be made to ineligible entities and to
                       strengthen SBA’s ability to service loans
                       appropriately.
21-03   12/1/2020      Establish post-payment audit procedures, using       12/1/2020   2/28/2022
                       a risk-based approach, to verify the accuracy and
                       completeness of all subsidy payments to lenders
                       and include reviews of payments made to loans
                       that changed from liquidation status to regular
                       servicing status, and remedy improper payments
                       in accordance with the Payment Integrity Act of
                       2019.
21-04   12/18/2020     Determine the impact on the outstanding              2/1/2021    9/21/2021
                       guarantee and eligibility for forgiveness of loans
                       determined to be not in conformance with the
                       CARES Act and related legislation.
21-04   12/18/2020     Update and enforce the existing Procedural           3/26/2021   9/17/2021
                       Notice 5000-20049 to require the adequate
                       review and approval of Section 1112 payments
                       made to lenders and to determine that the
                       necessary documentation is maintained to
                       substantiate the payment amount.
21-06   1/11/2021      Promptly identify PPP loans that have not been       3/4/2021    2/18/2022
                       fully disbursed and follow-up with the lenders to
                       stop $280 million in potential improper loan
                       disbursements.
21-07   1/14/2021      Review the loans identified as potentially           1/14/2021   12/1/2021
                       ineligible to determine if the businesses met
                       eligibility requirements. If not, take appropriate
                       action related to loan guaranty and forgiveness.
21-08   2/3/2021       Require responsible personnel to execute a           2/1/2021    4/30/2022
                       contract for foreclosure and real estate services
                       to ensure the procurement of services are
                       obtained and authorized in accordance with the
                       Federal Acquisition Regulation requirements.
21-08   2/3/2021       Ensure that vendors used to provide foreclosure      2/1/2021    4/30/2022
                       and real estate services are registered in SAM as
                       required.
21-08   2/3/2021       Ratify the over $10.8 million in payments in         —           —
                       accordance with the FAR and 48C.F.R. § 1.602-3.
21-09   3/15/2021      Review the OIG identified potential duplicate        3/31/2021   6/30/2022
                       disbursements for eligibility and take action to
                       recover any improper payments as applicable.
21-09   3/15/2021      Review SBA controls related to all PPP loan          3/31/2021   6/30/2022
                       reviews to ensure that duplicate loans are not
                       forgiven and not subject to an SBA guaranty, as
                       appropriate.




                                            Spring 2022 Semiannual Report to Congress | 28
U.S. Small Business Administration | Office of Inspector General

21-09      3/15/2021       Strengthen E-Tran controls for future PPP type      3/23/2021   4/30/2022
                           programs, which includes keeping E-Tran
                           controls that align with program requirements
                           on at all times.
21-09      3/15/2021       Review the issues that SBA identified involving     3/23/2021   4/30/2022
                           the actions of lenders, such as providing
                           incorrectly formatted data and submitting the
                           same application through multiple platforms and
                           determine how to strengthen controls and
                           guidance as appropriate to ensure lenders meet
                           program requirements for future PPP type
                           programs.
21-11      3/30/2021       Enforce standard operating procedures requiring     3/24/2021   11/30/2021
                           clearly defined performance goals and include
                           performance targets in all future SBDC and WBC
                           cooperative agreements and grants to
                           objectively measure performance results.
21-11      3/30/2021       Collect and analyze the CARES Act                   3/24/2021   11/30/2021
                           entrepreneurial development cooperative
                           agreement recipient’s performance results and
                           establish a framework for setting goals for
                           technical assistance programs in response to
                           future disasters. Retain the analysis in program
                           files for future guidance.
21-14      5/4/2021        Implement financial oversight procedures for the    5/4/2021    12/31/2021
                           WBC program that ensure the program office
                           enforces WBC cooperative agreement
                           requirements. Program officials should ensure
                           WBCs use federal funds only for allowable,
                           allocable, and reasonable expenses, adhere to
                           contract award procedures, and separate project
                           costs by funding source.
21-14      5/4/2021        Remedy $523,790 in unsupported matching             5/4/2021    9/29/2024
                           funds, unsupported program income, and the
                           resulting portion of the federal funds reimbursed
                           for the unmet match, and $186,537 in
                           unsupported expenses.
21-14      5/4/2021        Recover $31,215 for improperly awarded              5/4/2021    9/29/2024
                           contracts and $31,424 in unallowable or
                           unallocable expenses.
21-14      5/4/2021        Implement policies and procedures for               5/4/2021    12/31/2021
                           conducting thorough financial compliance
                           reviews and coordinate with the Office of Field
                           Operations to train field office personnel
                           responsible for semiannual site visits.
21-14      5/4/2021        Establish policies holding program officials        5/4/2021    12/31/2021
                           accountable for promptly following up on
                           financial examination results and enforcing
                           cooperative agreement requirements.
21-14      5/4/2021        Require higher-level reviewers to clearly justify   5/4/2021    12/31/2021
                           and document approving or denying
                           disbursement of funds if the decisions differ
                           from the recommendations of lower-level
                           reviewers; justification documentation should be
                           kept in the official cooperative agreement file.




29 | Spring 2022 Semiannual Report to Congress
               U.S. Small Business Administration | Office of Inspector General

21-14   5/4/2021       Review expenses for the $28,089 reallocation of     5/4/2021    9/29/2024
                       budget expenses we detailed in this report to
                       ensure these costs are allowable and document
                       the rationale for the reallocation or recover
                       costs that are unallowable.
21-14   5/4/2021       Require program officials to enforce the            5/4/2021    12//31/2021
                       cooperative agreement terms and conditions
                       and deobligate or withhold payments if WBCs do
                       not submit accurate financial reports on time.
21-15   5/6/2021       Develop a process to remove any fraudulent          3/3/2022    3/31/2022
                       loans and related UCC filing fees from its
                       financial records.
21-15   5/6/2021       Review over 150,000 returned billing statements     3/3/2022    3/31/2022
                       and resolve any that involve identity theft then
                       refer fraudulent loans to OIG.
21-16   5/12/2021      Collaborate with the Chief Financial Officer to     8/6/2021    9/30/2021
                       ensure a timely and complete reconciliation is
                       performed on the population subject to
                       sampling for improper payment reviews.
21-16   5/12/2021      Coordinate with the Office of Disaster              8/6/2021    9/30/2021
                       Assistance’s statistician to ensure the estimated
                       improper payment amounts are calculated
                       consistently and the sampling methodology
                       adequately describes the criteria for
                       stratification.
21-16   5/12/2021      Implement additional preventative and               2/3/2022    5/31/2022
                       monitoring controls to determine the eligibility
                       of borrowers prior to approval.
21-16   5/12/2021      Ensure there is adequate training of staff at the   2/3/2022    5/31/2022
                       National Guaranty Purchase Centers.
21-16   5/12/2021      Collaborate with the Chief Financial Officer to     2/3/2022    5/31/2022
                       ensure a timely and complete reconciliation is
                       performed on the population subject to
                       sampling for improper payment reviews.
21-16   5/12/2021      Formally document and implement additional          8/6/2021    9/30/2021
                       preventative and monitoring controls to
                       determine the eligibility of borrowers prior to
                       approval and disbursement.
21-16   5/12/2021      Ensure there is adequate training of staff at the   8/6/2021    9/30/2021
                       Processing and Disbursement Center.
21-18   7/12/2021      Enforce the requirements of the February 2021       7/12/2021   6/30/2022
                       COVID-19 Workplace Safety Plan by consistently
                       applying occupancy and exposure tracking and
                       accurately recording and maintaining supporting
                       documentation for all reported COVID-19 cases.




                                            Spring 2022 Semiannual Report to Congress | 30
U.S. Small Business Administration | Office of Inspector General


Significant Recommendations from this Reporting Period
Report   Date Issued     Title                                    Recommendation
Number
22-01    10/7/2021       SBA's Emergency EIDL Grants to Sole      Review the applications of sole proprietors and
                         Proprietors and Independent              independent contractors that included numbers
                         Contractors                              of employees but no Employer Identification
                                                                  Number; and remedy the $3.5 billion disbursed
                                                                  to sole proprietors and $1 billion disbursed to
                                                                  independent contractors that exceeded the
                                                                  amount allowed by SBA’s policy.
22-03    10/28/2021      SBA’s Controls Over Cash Contributions   Establish and implement additional controls to
                         and Gifts, Fiscal Years 2021 and 2020    ensure responsible officials follow SOP 90 75 4, as
                                                                  amended, closing out all cosponsored activities
                                                                  within 90 days as required.
22-03    10/28/2021      SBA’s Controls Over Cash Contributions   Revise the cosponsorship agreement used for
                         and Gifts, Fiscal Years 2021 and 2020    National Small Business Week to eliminate and
                                                                  clarify conflicting instructions to ensure all
                                                                  cosponsored activities can be closed out within
                                                                  90 days in accordance with SOP 90 75 4, as
                                                                  amended.
22-03    10/28/2021      SBA’s Controls Over Cash Contributions   Reconcile cash contributions reported by the
                         and Gifts, Fiscal Years 2021 and 2020    fiscal agent using the cosponsors joinder
                                                                  agreements or the Small Business Week
                                                                  Cosponsorship Account bank statements to
                                                                  ensure the report is accurate and reliable.
22-04    11/8/2021       Independent Auditors’ Report on SBA’s    KPMG recommends the Administrator coordinate
                         Compliance with DATA Act Reporting       with the Associate Administrator for Capital
                                                                  Access to develop and enforce a plan to monitor
                                                                  lenders’ execution of their responsibilities in the
                                                                  loan origination and servicing process, including
                                                                  accurate and timely 1502 reporting, on an
                                                                  ongoing basis.
22-04    11/8/2021       Independent Auditors’ Report on SBA’s    KPMG recommends the Administrator coordinate
                         Compliance with DATA Act Reporting       with the Associate Administrator for Disaster
                                                                  Assistance to enforce that documentation is
                                                                  maintained to evidence changes to a loan and
                                                                  ensure that awarding actions are entered into the
                                                                  source systems in a timely manner.
22-04    11/8/2021       Independent Auditors’ Report on SBA’s    KPMG recommends the Administrator coordinate
                         Compliance with DATA Act Reporting       with the Acting Chief Financial Officer to update
                                                                  the source of the Awardee/Recipient Legal Entity
                                                                  Name data element mapping to be the business
                                                                  legal name field from the application for
                                                                  Emergency EIDL grants and EIDLs.
22-04    11/8/2021       Independent Auditors’ Report on SBA’s    KPMG recommends the Administrator coordinate
                         Compliance with DATA Act Reporting       with the Acting Chief Financial Officer to
                                                                  implement validation controls to verify the
                                                                  accuracy of the Legal Entity Congressional District
                                                                  and Primary Place of Performance Congressional
                                                                  District data elements.




31 | Spring 2022 Semiannual Report to Congress
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued         Title                                   Recommendation
Number
22-04    11/8/2021           Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             Compliance with DATA Act Reporting      with the Acting Chief Financial Officer to, in
                                                                     conjunction with relevant program offices,
                                                                     establish and implement a consistent and
                                                                     accurate set of rules to classify the Business
                                                                     Types data element in accordance with DAIMS
                                                                     and the appropriate business size and type
                                                                     criteria.
22-04    11/8/2021           Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             Compliance with DATA Act Reporting      with the Acting Chief Financial Officer to provide
                                                                     notification to Treasury’s DATA Act Broker
                                                                     Program Management Office of the Action Type
                                                                     element that was reported incorrectly due to the
                                                                     reporting process in place for resubmissions of
                                                                     transactions.
22-04    11/8/2021           Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             Compliance with DATA Act Reporting      with the Acting Chief financial Officer to, prior to
                                                                     the end of the reporting period, perform a review
                                                                     of all cross-check warnings on the submission
                                                                     files and identify action plans for remediation in
                                                                     the current or subsequent periods.
22-04    11/8/2021           Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             Compliance with DATA Act Reporting      with the Acting Chief Financial Officer to
                                                                     implement a sufficient review of the
                                                                     reconciliation between File B and File C to ensure
                                                                     all variances are researched and necessary
                                                                     corrections are made to the submission prior to
                                                                     the SAO’s certification.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                     Access to perform a thorough review of PPP loan
                                                                     guarantee approvals in the 2021 cohort. Based
                                                                     on the review, determine the impact on the
                                                                     outstanding loan guarantee and the eligibility for
                                                                     forgiveness of loans that are determined to not
                                                                     be in conformance with the CARES Act and
                                                                     related legislation and program requirements.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Acting Chief Financial Officer to, based
                                                                     on the results of the loan guarantee review
                                                                     process for the 2021 cohort of PPP loan
                                                                     guarantees, assess the accounting
                                                                     considerations, including the impact on the
                                                                     consolidated financial statements, and record any
                                                                     necessary adjustments for loans determined to
                                                                     not be in conformance with the CARES Act and
                                                                     related legislation.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                     Access to design and implement controls to
                                                                     identify and review PPP loan guarantees with
                                                                     incomplete or inaccurate lender loan status
                                                                     reports.




                                                   Spring 2022 Semiannual Report to Congress | 32
U.S. Small Business Administration | Office of Inspector General

Report   Date Issued     Title                                   Recommendation
Number
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to determine the correct PPP loan
                                                                 balances and ensure the loan repository system is
                                                                 updated with the correct balance.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to develop and enforce a policy and
                                                                 controls that require the adequate training and
                                                                 monitoring of lenders to execute their
                                                                 responsibilities in the PPP loan servicing process.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to develop and enforce a policy and
                                                                 controls to monitor incomplete or inaccurate PPP
                                                                 lender loan status reports on an ongoing basis.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to, based
                                                                 on the results of the lender loan status reports
                                                                 review process for PPP loan guarantees, design
                                                                 and implement controls to assess the accounting
                                                                 considerations, including the impact on the
                                                                 consolidated financial statements, and record any
                                                                 necessary adjustments.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to develop and enforce a policy and
                                                                 controls that require the adequate review and
                                                                 validation of the outputs of the case
                                                                 management system.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to develop and enforce a policy and
                                                                 controls to monitor the results of the contractor’s
                                                                 loan review process including a review of loans
                                                                 with a ‘No Further Action’ determination.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to design adequate controls and
                                                                 processes to ensure forgiveness payments are
                                                                 not processed for loan guarantees that have not
                                                                 been sufficiently reviewed.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to develop and execute a thorough,
                                                                 formal review plan of the COVID-19 EIDLs and
                                                                 grants portfolios and determine which
                                                                 transactions were made to ineligible recipients
                                                                 and did not conform with the CARES Act and
                                                                 related legislation.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to implement controls that prevent or
                                                                 detect COVID-19 EIDLs from being approved that
                                                                 are not in conformance with the related
                                                                 legislation and program’s eligibility terms.



33 | Spring 2022 Semiannual Report to Congress
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued         Title                                   Recommendation
Number
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                     Access to update the Reference Guide to require
                                                                     a more thorough review to clear certain alerts
                                                                     and enforce the actions recommended by the
                                                                     Reference Guide to adequately address and
                                                                     mitigate the alerts prior to COVID-19 EIDLs
                                                                     approval.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                     Access to provide training for loan officers and
                                                                     team leads to reinforce their responsibilities in
                                                                     accordance with established and updated
                                                                     guidance and standard operating procedures.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Acting Chief Financial Officer to, based
                                                                     on the results of the review process for COVID-19
                                                                     EIDLs and grants, assess the accounting
                                                                     considerations, including the impact on the
                                                                     consolidated financial statements, and record any
                                                                     necessary adjustments for transactions
                                                                     determined not to be in conformance with the
                                                                     CARES Act and related legislation.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Acting Chief Financial Officer to design
                                                                     and implement controls to continue
                                                                     accumulating relevant, complete, and accurate
                                                                     data on which to base the subsidy re-estimate
                                                                     models for the PPP and COVID-19 EIDLs
                                                                     portfolios.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Acting Chief Financial Officer to ensure
                                                                     there are adequate review and approval controls
                                                                     over the re-estimate models for the PPP and
                                                                     COVID-19 EIDL portfolios by appropriate levels of
                                                                     management, including review and
                                                                     documentation of relevant data inputs,
                                                                     development of assumptions, and
                                                                     reasonableness for the selected assumptions
                                                                     used and the resulting estimates.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                     Access to continually evaluate the established
                                                                     policy for SOC 1 reports that requires new service
                                                                     organizations to provide a SOC 1 report over the
                                                                     control environment that is relevant and
                                                                     significant to the processing and recording of
                                                                     SBA’s transactions. If a SOC 1 report cannot be
                                                                     obtained, identify, and evaluate relevant controls
                                                                     at the service organizations that have an impact
                                                                     on SBA’s internal controls over financial
                                                                     reporting.




                                                   Spring 2022 Semiannual Report to Congress | 34
U.S. Small Business Administration | Office of Inspector General

Report   Date Issued     Title                                   Recommendation
Number
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to assess the risk posed by the service
                                                                 organization’s control environment and obtain
                                                                 sufficient assurance over the operating
                                                                 effectiveness of relevant and significant controls
                                                                 to determine the integrity of transactions
                                                                 processed on behalf of and recorded by SBA. If a
                                                                 SOC 1 report is obtained for the relevant control
                                                                 environment at the service organization.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator of Capital
                                                                 Access to continually evaluate the established
                                                                 policy for SOC 1 reports that requires new service
                                                                 organizations to provide a SOC 1 report over the
                                                                 control environment that is relevant and
                                                                 significant to the processing and recording of
                                                                 SBA’s transactions. If a SOC 1 report cannot be
                                                                 obtained, identify, and evaluate relevant controls
                                                                 at the service organizations that have an impact
                                                                 on SBA’s internal controls over financial
                                                                 reporting.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                 Access to perform a thorough review of
                                                                 Restaurant Revitalization awards issued and
                                                                 identify recipients that may not have been
                                                                 eligible to receive awards in accordance with the
                                                                 program’s terms, especially for recipients with
                                                                 flagged PPP loan guarantees.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                 Access to design and implement effective
                                                                 monitoring controls, to ensure that Restaurant
                                                                 Revitalization award recipients are complying
                                                                 with the program’s terms and to ensure
                                                                 complete, accurate, and timely reporting for the
                                                                 use of the award.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator for Disaster
                                                                 Assistance to design and implement effective
                                                                 monitoring controls, to ensure that SVOG award
                                                                 recipients are complying with the program’s
                                                                 terms and to ensure complete, accurate, and
                                                                 timely reporting for the use of the award.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to design
                                                                 and implement controls to ensure the accounting
                                                                 treatment established to record the Restaurant
                                                                 Revitalization and the SVOG program related
                                                                 balances is in accordance with U.S. Generally
                                                                 Accepted Accounting Principles and the basis for
                                                                 the appropriate treatment is sufficiently
                                                                 documented.




35 | Spring 2022 Semiannual Report to Congress
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued         Title                                   Recommendation
Number
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends that the Administrator
                             FY 2021 Financial Statements            coordinate with the Associate Administrators for
                                                                     Capital Access and Disaster Assistance to
                                                                     document the internal control system and
                                                                     processes related to the implementation of new
                                                                     or expanded programs from new legislation.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends that the Administrator
                             FY 2021 Financial Statements            coordinate with the Associate Administrators for
                                                                     Capital Access and Disaster Assistance to develop
                                                                     and implement monitoring controls to ensure
                                                                     implementation of an effective internal control
                                                                     environment.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends that the Administrator
                             FY 2021 Financial Statements            coordinate with the Acting Chief Financial Officer
                                                                     to, in conjunction with relevant program offices,
                                                                     assess the effectiveness of key process level
                                                                     controls to respond to the identified risks.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends that the Administrator
                             FY 2021 Financial Statements            coordinate with the Acting Chief Financial Officer
                                                                     to develop and implement a sufficient plan to
                                                                     test and monitor the design, implementation,
                                                                     and operating effectiveness of key, relevant
                                                                     controls that affect financial reporting and
                                                                     compliance with relevant laws and regulations.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statement             with the Associate Administrator for Capital
                                                                     Access to perform a review of the payments
                                                                     made by SBA for covered loans under the Debt
                                                                     Relief Program to identify, review, and remediate
                                                                     any potential over or under payments made on
                                                                     the related loans.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                     Access to consider allocating resources to
                                                                     implement enforcement processes that ensure
                                                                     the accounts of separated users are removed
                                                                     timely from SBA systems.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                     Access to validate that the identified accounts of
                                                                     separated users were not utilized after
                                                                     separation had occurred.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                     Access to ensure individuals responsible for
                                                                     removing accounts of separated users are aware
                                                                     of the process and periodically sent reminders of
                                                                     their responsibilities.
22-05    11/15/2021          Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                             FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                     Access to implement controls and a monitoring
                                                                     process to ensure that patches applied to the
                                                                     database and operating system and application
                                                                     changes are appropriately tested prior to being
                                                                     moved into the production environment.




                                                   Spring 2022 Semiannual Report to Congress | 36
U.S. Small Business Administration | Office of Inspector General

Report   Date Issued     Title                                   Recommendation
Number
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                 Access to update the system configuration
                                                                 management plan to require internal control
                                                                 documentation for patch management and
                                                                 application changes as required by the
                                                                 Government Accountability Office’s Standards for
                                                                 Internal Control in the Federal Government.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Associate Administrator for Capital
                                                                 Access to periodically train personnel involved
                                                                 with the implementation of database and
                                                                 operating system patches, and the review and
                                                                 approval of application changes, to follow the
                                                                 respective controls and requirements of the
                                                                 patch management and application change
                                                                 management processes in accordance with
                                                                 existing policies.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to update
                                                                 the risk assessment regarding the evaluation of
                                                                 internal controls to ensure it includes all
                                                                 significant programs, key processes, and other
                                                                 material line items on the consolidated financial
                                                                 statements.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to, in
                                                                 conjunction with relevant program offices,
                                                                 perform and document the internal control
                                                                 evaluation over all programs. This should include
                                                                 entity level controls, manual controls, general
                                                                 information technology controls, and system
                                                                 application controls covering key financial
                                                                 statement line items and risks.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to update
                                                                 the existing policy and implement adequate
                                                                 controls to ensure that the statement of
                                                                 assurances provided by the program offices are
                                                                 adequately documented and reviewed for
                                                                 completeness and accuracy to provide a
                                                                 sufficient basis to support the Administrator’s
                                                                 statement of assurance.
22-05    11/15/2021      Independent Auditors’ Report on SBA’s   KPMG recommends the Administrator coordinate
                         FY 2021 Financial Statements            with the Acting Chief Financial Officer to address
                                                                 the control deficiencies over transactions arising
                                                                 from the implementation of the CARES Act and
                                                                 related legislation by working with the Office of
                                                                 Capital Access and the Office of Disaster
                                                                 Assistance to implement the recommendations in
                                                                 Appendix I–Material Weaknesses.




37 | Spring 2022 Semiannual Report to Congress
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued         Title                                      Recommendation
Number
22-06    11/30/2021          COVID-19 EIDL Program Recipients on        Use Treasury’s Do Not Pay (DNP) analysis to
                             the Department of Treasury's Do Not        systemically flag COVID-19 EIDL and Emergency
                             Pay List                                   EIDL grant recipients who were found in
                                                                        Treasury’s DNP system and not previously
                                                                        reported by OIG. Review the applications and
                                                                        determine whether they are deemed ineligible. If
                                                                        the applicant is deemed ineligible, recover any
                                                                        disbursed funds, and flag the application as
                                                                        ineligible.
22-06    11/30/2021          COVID-19 EIDL Program Recipients on        Implement prepayment and pre-award
                             the Department of Treasury's Do Not        procedures and use the batch match or
                             Pay List                                   continuous monitoring functions available in
                                                                        Treasury’s DNP system to identify potentially
                                                                        ineligible applicants before disbursing COVID-19
                                                                        EIDL program funds.


22-07    1/18/2022           SBA’s Oversight of the Grant Recipient’s   Require the grant recipient to enhance its
                             Implementation of the CARES Act            marketing and outreach strategy to include plans
                             Resource Partners Training Portal          to reach a greater number of small businesses
                                                                        and resource partner counselors and mentors.
                                                                        The grant recipient should also set clear
                                                                        performance goals with realistic targets before
                                                                        SBA awards any additional funds for the COVID-
                                                                        19 resource and training portal, as required by
                                                                        CARES Act Section 1103(c)(2).
22-07    1/18/2022           SBA’s Oversight of the Grant Recipient’s   Implement procedures for enhanced financial
                             Implementation of the CARES Act            oversight of the CARES Act Resource Partner
                             Resource Partners Training Portal          Training Portal program to ensure the program
                                                                        office enforces the grant requirements and
                                                                        follows federal procurement standards when
                                                                        using noncompetitive contracting options. The
                                                                        requirements include a price or cost analysis for
                                                                        awards that exceed the simplified acquisition
                                                                        threshold. Another requirement ensures the
                                                                        grant recipient adheres to the terms in the notice
                                                                        of award.
22-07    1/18/2022           SBA’s Oversight of the Grant Recipient’s   Evaluate whether the contract costs for web
                             Implementation of the CARES Act            development services and media services are
                             Resource Partners Training Portal          reasonable and remedy any violations.
22-07    1/18/2022           SBA’s Oversight of the Grant Recipient’s   Assess and recover the amount spent on the
                             Implementation of the CARES Act            unallowable contracted project management
                             Resource Partners Training Portal          services expenses incurred during the
                                                                        performance of the grant.
22-07    1/18/2022           SBA’s Oversight of the Grant Recipient’s   Recover the $100,000 paid for unallowable pre-
                             Implementation of the CARES Act            award project management expenses.
                             Resource Partners Training Portal
22-08    2/14/2022           SBA’s Business Development Assistance      Implement a standard process to approve initial
                             to 8(a) Program Participants               business plans and monitor to ensure that
                                                                        business plans are reviewed annually, to include
                                                                        appropriate updates for specific targets,
                                                                        objectives, and goals for the business
                                                                        development of program participants, in
                                                                        accordance with 13 CFR 124.403(a) and section
                                                                        7(j)(10)(D) of the Small Business Act.




                                                     Spring 2022 Semiannual Report to Congress | 38
U.S. Small Business Administration | Office of Inspector General

Report   Date Issued     Title                                   Recommendation
Number
22-08    2/14/2022       SBA’s Business Development Assistance   Implement a standard process to capture, track,
                         to 8(a) Program Participants            and recognize substantial achievement of the
                                                                 specific targets, objectives, and goals for the
                                                                 areas of finance, marketing, and management on
                                                                 8(a) program participant business plans, in
                                                                 accordance with 13 CFR 124.112(f) and section
                                                                 7(j)(10)(A) of the Small Business Act.
22-08    2/14/2022       SBA’s Business Development Assistance   Establish outcome-based performance goals and
                         to 8(a) Program Participants            measurements to assess whether the program
                                                                 achieved business development objectives,
                                                                 including the number of graduated 8(a) firms in
                                                                 accordance with the measure of success in
                                                                 section 101(b)(2) of the Business Opportunity
                                                                 Development Reform Act of 1988.
22-08    2/14/2022       SBA’s Business Development Assistance   Implement a process that uses outcome-based
                         to 8(a) Program Participants            performance goals for regular data-driven
                                                                 reviews and align program leaders’ personal
                                                                 performance plans with the goals so program
                                                                 office leaders are held accountable for improving
                                                                 program data quality, identifying effective
                                                                 practices, and validating promising initiatives that
                                                                 align with OMB Circular A-11 Part 6–The Federal
                                                                 Performance Framework for Improving Program
                                                                 and Service Delivery guidance.
22-08    2/14/2022       SBA’s Business Development Assistance   Implement a process to ensure the systematic
                         to 8(a) Program Participants            collection of accurate and complete data on
                                                                 program results and operations to make sure all
                                                                 program reporting requirements are met, in
                                                                 accordance with section 7(j)(16)(A) of the Small
                                                                 Business Act and Standards for Internal Control in
                                                                 the Federal Government Principles for
                                                                 Information and Communication.
22-08    2/14/2022       SBA’s Business Development Assistance   Implement requirements for management to
                         to 8(a) Program Participants            monitor that Business Opportunity Specialists
                                                                 consistently assess program participant’s
                                                                 development needs, counsel participants,
                                                                 conduct annual field visits, and maintain required
                                                                 documentation, as required by standard
                                                                 operating procedures.
22-08    2/14/2022       SBA’s Business Development Assistance   Ensure all employees performing Business
                         to 8(a) Program Participants            Opportunity Specialist duties maintain a current
                                                                 Federal Acquisition Certification in Contracting
                                                                 Level 1 Certification within a year of appointment
                                                                 in accordance with section 4(g) of the Small
                                                                 Business Act.
22-08    2/14/2022       SBA’s Business Development Assistance   Use lessons learned from servicing 8(a) firms in
                         to 8(a) Program Participants            an entirely virtual environment to coordinate
                                                                 district office resources and share best practices
                                                                 to equitably serve all 8(a) program participants.
                                                                 Align assigned Business Opportunity Specialist
                                                                 staffing levels accordingly to be consistent with
                                                                 ideal workload ratios as determined by the
                                                                 program office.
22-09    2/28/2022       SBA’S Paycheck Protection Program       Develop a plan to ensure remaining forgiveness
                         Loan Review Processes                   reviews and remittances are completed within 90
                                                                 days as required by the CARES Act.



39 | Spring 2022 Semiannual Report to Congress
                     U.S. Small Business Administration | Office of Inspector General

Significant Management Decisions with which OIG Disagrees
There were no significant management decisions OIG disagrees with during this reporting period.

Significant Revised Management Decisions
There were no significant revised management decisions during this reporting period.

Federal Financial Management Improvement Act
The OIG’s Independent Public Accountant, KPMG, did not render an opinion on the compliance with the
Federal Financial Management Improvement Act, but their test work in the FY 2021 financial statement
disclosed instances in which SBA’s financial management systems did not substantially comply with
federal financial management systems requirements and applicable federal accounting standards. The
results disclosed no instances in which SBA’s financial management systems did not substantially comply
with the United States Standard General Ledger at the transaction level.

Instances of Interference
There were no attempts by SBA officials to interfere with OIG independence during this reporting period.




                                                 Spring 2022 Semiannual Report to Congress | 40
U.S. Small Business Administration | Office of Inspector General

Appendix D. Investigations Reporting Statistics
Investigative Reports Issued
 Report Type                                                                                  Number of Reports
 Report of Investigation                                                                      104
 Preliminary Case Closing Reports of Investigation                                            54
 Total                                                                                        158

Persons Referred for Prosecution
 Referred to                                                                                  Number of Persons
 Department of Justice                                                                        77
 State Attorney                                                                               3
 Local Attorney                                                                               —
 Total                                                                                        80
*Number includes persons and entities referred for prosecution.

Pandemic-Related Investigative Statistics
 SBA OIG                        Investigations       Indict/Complaint      Arrests             Convictions
 PPP/EIDL*                      334                  97                    66                  84
 Investment Fraud               1                    1                     1                   1
 Total                          335                  98                    67                  85

*PPP stands for Paycheck Protection Program. EIDL stands for Economic Injury Disaster Loan.

Whistleblower Retaliation Cases
There were no OIG investigations involving Whistleblower retaliation during the reporting period.

Investigations Involving a Senior Government Employee Where Misconduct Was
Substantiated
There were no OIG investigations involving a senior government employee where misconduct was
substantiated during the reporting period.

Investigations Involving a Senior Government Employee That Are Closed and Not
Disclosed to the Public
There were no nonpublic, closed investigations of senior government employees during this semiannual
period.




41 | Spring 2022 Semiannual Report to Congress
                   U.S. Small Business Administration | Office of Inspector General

Appendix E. Legal Actions Summary
Legal Actions, October 1, 2021–March 31, 2022
State    Program    Jointly With     Alleged Violations Prosecuted                   Legal Action



FL       BL         FBI, IRS-CI      Subject submitted fraudulent PPP loan           Subject was sentenced to 180
                                     applications to different federally insured     months in incarceration and 5-year
                                     credit unions and banks on behalf of            supervised release. Also ordered to
                                     businesses that did not exist for residents     pay $1.5 million in restitution.
                                     of senior living facilities. Subject received
                                     over $1.5 million in fraudulent loan
                                     proceeds.
TX       BL         USPIS, FHFA,     Subject made material misrepresentations        Subject was sentenced to 110
                    MLARS            to a financial institution and filed seven      months in incarceration, 3 years
                                     fraudulent loan applications seeking more       supervised release and ordered to
                                     than $6.7 million in forgivable loans           pay restitution in the amount of
                                     through the PPP. Subject used the loan          $1,689,952.
                                     proceeds for lavish personal purchases.


NJ       BL         FDIC, FBI        Subjects participated in scheme to defraud      Individual was sentenced to 18
                                     SBA of $5 million by providing false            months incarceration and 3 years
                                     statements in multiple PPP applications.        of supervised release. Another
                                                                                     suspect was sentenced to 18
                                                                                     months incarceration and 3 years
                                                                                     of supervised release. They were
                                                                                     ordered to pay $3.1 million in
                                                                                     restitution.
FL       BL         FDIC-OIG, USSS   Subjects conspired with others to execute       Subject 1 was sentenced to 60
                                     a scheme to defraud various financial           months incarceration and 5 years
                                     institutions by opening over 700 bank           of supervised release. Suspect 2
                                     accounts and shell companies with stolen        was sentenced to 42 months
                                     and synthetic identities.                       incarceration and 5 years
                                                                                     supervised release. Suspect 3 was
                                                                                     sentenced to 12 months and 2
                                                                                     years supervised release. They
                                                                                     were ordered to pay over $21
                                                                                     million in restitution.
NY       BL/DL      FBI, IRS-CI      Subjects used the identities of other           Subject was sentenced to 72
                                     individuals to submit online applications to    months incarceration and 3 years
                                     SBA and five financial institutions for over    of supervised release. Other
                                     $7 million in loans through the PPP and         subject was ordered to pay
                                     EIDL programs.                                  restitution of $3 million.




                                                  Spring 2022 Semiannual Report to Congress | 42
U.S. Small Business Administration | Office of Inspector General

CA        BL       FBI, IRS-CI   As part of the scheme, subjects conspired    Subject 1 was sentenced to 72
                                 with others to submit over 150 fraudulent    months incarceration and 4 years
                                 loan applications and obtain over $18        of supervised release. Subject 2
                                 million in CARES Act funds. Subjects         was sentenced to 12 months
                                 purchased luxury homes, gold coins,          incarceration and 3 years
                                 diamonds, jewelry, luxury watches, and       supervised release. Subject 3 was
                                 cryptocurrency.                              sentenced to 10 months of
                                                                              probation. Subject 4 was
                                                                              sentenced to 30 months
                                                                              incarceration and 3 years
                                                                              supervised release. Subject 5 was
                                                                              sentenced to 30 months
                                                                              incarceration and 3 years
                                                                              supervised release. Subjects were
                                                                              ordered to pay over $14 million in
                                                                              restitution.
FL        BL       FBI, IRS-CI   Subjects forged bank statements and          Subject 1 was sentenced to 37
                                 made material misrepresentations to a        months in incarceration and 3
                                 financial institution to gain approval for   years supervised release. Subject 2
                                 PPP loans, obtaining over $2.7 million.      was sentenced to 20 months in
                                                                              incarceration and 3 years
                                                                              supervised release. Subject 3 was
                                                                              sentenced to 24 months in
                                                                              incarceration and 3 years
                                                                              supervised release. They were
                                                                              ordered to pay $2.7 million in
                                                                              restitution.
IN        GC       FDIC, FBI     Subjects originated SBA loans on behalf of   Subject 1 was sentenced to 68
                                 various financial institutions and           months incarceration and 3 years
                                 fraudulently obtained guarantees for loans   of supervised release. Subject 2
                                 that the SBA deemed ineligible and           was sentenced to 57 months
                                 provided false information in connection     incarceration and 3 years of
                                 with SBA loan originations to make them      supervised release. Subject 3 was
                                 appear eligible. The subjects hid signs of   sentenced to 28 months
                                 ineligibility from SBA by knowingly          incarceration and 2 years of
                                 misrepresenting the use of SBA loan          supervised release. Subject 4 was
                                 proceeds and unlawfully diverting            sentenced to 28 months
                                 previously denied loan applications into     incarceration and 2 years of
                                 expedited approval channels.                 supervised release. They were
                                                                              ordered to pay over $6.9 million in
                                                                              restitution.
NY        BL       FBI           Subject made false statements to obtain      Subject was sentenced to 96
                                 PPP funding totaling $637,200. Subject       months incarceration followed by 5
                                 also made false statements related to        years of supervised release and
                                 healthcare fraud scheme.                     restitution of $3.6 million.
OR        BL/DL    FBI, IRS-CI   Subjects conspired to submit nine PPP and    Subject 1 was sentenced to 48
                                 EIDL loans securing over $3.5 million by     months incarceration and 5 years
                                 using false payroll information and          supervised release. Subject 2 was
                                 providing materially false information on    sentenced to 14 days incarceration
                                 loan applications.                           and 3 years supervised release.
                                                                              Subjects were ordered to pay $4
                                                                              million in restitution.
OR        BL/DL    FBI, TIGTA,   Individual defrauded the government of       Subject was sentenced to 21
                   INTERPOL      over $884,000 in obligated PPP and EIDL      months incarceration and 5 years
                                 funds.                                       supervised release. Subject was
                                                                              ordered to pay $910,773 in
                                                                              restitution.




43 | Spring 2022 Semiannual Report to Congress
               U.S. Small Business Administration | Office of Inspector General

CA     BL       FBI, IRS-CI,      Several subjects planned a scheme to           Subject 1 was sentenced to 12
                FRBO, USSS,       unlawfully enrich themselves by                months incarceration and 3 years
                TIGTA             submitting false and fraudulent loan           of supervised release. Subject 2
                                  applications for over $2 million.              was sentenced to 18 months in
                                                                                 incarceration and 3 years of
                                                                                 supervised release. Subjects were
                                                                                 ordered to pay $2 million in
                                                                                 restitution and a fine of $1 million.
SC     GC       DCIS, USDA,       Subjects created fictitious documents          Subjects were sentenced to 3 years
                AFOSI             which were submitted to SBA in order to        supervised release, 100 hours of
                                  remain in the 8(a) program. They received      community service, and ordered to
                                  over $85 million in contracts, primarily       pay a $500,000 fine.
                                  from the US Air Force.
NC     BL/DL    FDIC, IRS-CI,     Individuals defrauded SBA and authorized       Subject 1 was sentenced to 72
                TICTA             lenders within the PPP/EIDL programs by        months incarceration and 3 years
                                  claiming false business operations. They       supervised release. Subject 2 was
                                  fraudulently received $1.3 million.            sentenced to 66 months
                                                                                 incarceration and 3 years
                                                                                 supervised release. Subject 3 was
                                                                                 sentenced to 60 months
                                                                                 incarceration, 3 years supervised
                                                                                 release. Individuals were ordered
                                                                                 to pay $1.3 million in restitution.
OR     BL/DL    IRS-CI            Subject devised a scheme involving PPP         Subject was sentenced to 61
                                  and EIDL loans using a false identity,         months incarceration, 4 years
                                  purchasing a 2020 Ford F-350 truck and a       supervised release, and was
                                  Tesla Model X using a counterfeit driver’s     ordered to pay $856,378 in
                                  license.                                       restitution.
GA     BL       TIGTA             Subject made multiple false statements         Subject was sentenced to 36
                                  and obtained two PPP loans over $1.2           months of confinement, 36 months
                                  million.                                       of supervised released, and
                                                                                 ordered to pay $802,301 in
                                                                                 restitution.
WA     BL/DL    FBI, FDIC-OIG,    Subject submitted 26 fraudulent PPP            Subject was sentenced to 48
                TIGTA, IRS-CI,    applications and 13 EIDL applications to       months in incarceration, 3 years
                HSI, HHS-OIG      federally insured financial institutions and   supervised release, and ordered to
                                  SBA seeking over $3.5 million in COVID-19      pay $1.4 million in restitution.
                                  relief funds.
AZ     GC       DCIS, Army CID,   Several individuals falsely certified that     Subject was sentenced to 3 years
                AFOSI             they met certain requirements to bid on        of probation and ordered to pay
                                  contracts that were set aside for              $250,000 in restitution.
                                  companies that qualified under the
                                  Historically Underutilized Business Zones
                                  (HUBZone) program.
SC     BL       TIGTA, IRS-CI     Subject submitted PPP application              Subject was sentenced to 24
                                  falsifying employee and revenue                months incarceration and 3 years
                                  information with resulting losses totaling     supervised release. Subject was
                                  over $1 million, misused proceeds for          ordered to pay $1 million in
                                  luxury items, gambling, and travel.            restitution.
USVI   BL       IRS-CI, USSS      Subject made false statement to obtain         Subject was sentenced to 33
                                  several PPP loans in the amount of             months of incarceration, 4 years
                                  $794,287.                                      supervised release, and ordered to
                                                                                 pay $383,397 in restitution.
NY     BL       FBI, IRS-CI       Subject submitted fraudulent documents         Individual was sentenced to 60
                                  of inflated employee payroll documents to      months incarceration, 3 years of
                                  obtain multiple PPP loans over $5 million.     supervised release, and $5 million
                                  Subject misused the proceeds for luxury        in restitution.
                                  items, vehicle, and travel.



                                              Spring 2022 Semiannual Report to Congress | 44
U.S. Small Business Administration | Office of Inspector General

DC        BL       FBI                 Subject made false assertions and               Subject was sentenced to 46
                                       certifications concerning PPP loans totaling    months in incarceration and 2
                                       $1.1 million.                                   years supervised release. Subject
                                                                                       was ordered to pay $1.4 million in
                                                                                       restitution.
TX        BL       USPIS               Business that was not operating before the      Subject was sentenced to 8 months
                                       COVID-19 pandemic applied for and               incarceration and 12 months
                                       received $1.1 million in PPP funds.             supervised release. Subject was
                                                                                       ordered to pay $997,486 in
                                                                                       restitution.
KY        DL       USSS                Subject made multiple false statements          Subject was sentenced to 12
                                       and obtained loan proceeds.                     months of incarceration and 3
                                                                                       years supervised release.
CO        DL       USSS                Subject submitted fraudulent EIDL               Subject was sentenced to 32
                                       applications to SBA on behalf of more than      months in incarceration, 3 years
                                       70 companies. Received over $4.4 million        supervised release, and to pay
                                       in fraudulent proceeds.                         $622,683 in restitution.
RI        BL       FBI, FDIC, IRS-CI   Subjects obtained PPP funding purporting        Subject was sentenced to 56
                                       to own three restaurants.                       months incarceration and 3 years
                                                                                       of supervised release. Subject was
                                                                                       sentenced to 6 months home
                                                                                       confinement, a fine $5,000 and 3
                                                                                       years supervised release.
TX        GC       DOJ ATD, Army       Individuals participated in a pass-through      Suspects were debarred for 36
                   CID, GSA-OIG,       scheme to defraud the SBA Service-              months.
                   VA-OIG, DCIS        Disabled Veteran-Owned small business
                                       program.
CO        GC       DCIS and Army       Fraud involving two construction                Civil judgment ordered to pay $1.1
                   CID                 companies in violation of the 8a program.       million.

VA        BL       FDIC, IRS-CI        As part of a scheme, subject submitted          Subject was sentenced to 33
                                       fraudulent loan applications and obtained       months incarceration and 2 years
                                       over $2 million in CARES Act funds.             supervised release. Subject was
                                                                                       ordered to pay $2.5 million in
                                                                                       restitution and a $15,000 fine.
AK        BL       FBI                 Individual applied for a PPP loan on their      Subject negotiated through a civil
                                       joint business without consent and              settlement agreement in the
                                       subsequently falsified PPP loan                 amount of $397,900.
                                       documentation to obtain funding totaling
                                       $1 million.
VA        GC       NASA                Subject falsely certified as a Woman-           Subject was sentenced to 6 months
                                       Owned Small Business and misrepresented         incarceration and 3 years of
                                       to the federal government and prime             supervised release. Subject was
                                       contractors in order to qualify for set-aside   sentenced to 12 months of
                                       contracting opportunities.                      unsupervised release. Two subjects
                                                                                       were sentenced to 12 months of
                                                                                       probation with a $5,000 fine.
                                                                                       Subjects were ordered to pay $1
                                                                                       million in restitution.
RI        BL       FBI, FDIC, IRS-CI   Subject made false statements and               Subject was sentenced to 70
                                       fraudulently applied for more than $4.7         months incarceration, 3 years of
                                       million in PPP loans.                           supervised release, and ordered to
                                                                                       pay $599,251 in restitution.
OK        BL       BGFRS, FBI          Individual created fraudulent documents,        Individual was sentenced to 24
                                       businesses and false identities and             months incarceration, 1 year of
                                       received $125,900 in loan proceeds.             supervised release, and ordered to
                                                                                       pay $25,906 in restitution.




45 | Spring 2022 Semiannual Report to Congress
                           U.S. Small Business Administration | Office of Inspector General

 IA            BL             FRB-OIG, FDIC-      Subject generated unlawful revenue and        Subject was sentenced to 9 months
                              OIG, FBI            fees for employers and fraudulently           incarceration and 4 years and 2
                                                  obtained SBA loan guarantees upward of        months of supervised release.
                                                  $4.6 million.                                 Subject was ordered to pay $4.5
                                                                                                million in restitution.
 GA            DL             USSS, SSA-OIG       Subject unlawfully obtained an EIDL in the    Subject was sentenced to 48
                                                  amount of $150,000 for a non-existent         months incarceration, restitution
                                                  business and then used the proceeds for       of $150,000 and a $5,000 fine.
                                                  personal travel expenses, shopping sprees,
                                                  cash withdrawals, and a large wire transfer
                                                  to a personal associate.
 CO            BL/DL          USSS, DOJ           Subject submitted false and fraudulent        Subject was sentenced to 30
                                                  EIDL and PPP applications and received        months incarceration and 3 years
                                                  over $660,000. The individual claimed and     of supervised release. Subject was
                                                  received over $40,000 in unemployment         ordered to pay $708,141 in
                                                  insurance benefits on behalf of ineligible    restitution.
                                                  family members without their knowledge
                                                  or consent.
 MO            GC             DCIS, GSA-OIG,      Subjects participated in a fraud scheme         Subject was sentenced to 28
                              Army- CID, IRS-     and conspired to operate companies with         months incarceration and 3 years
                              CI, VA-OIG,         straw owners who qualified as socially and      supervised release. Subject was
                              USDA-OIG, USSS,     economically disadvantaged or service-          sentenced to 10 years of
                              DOL-OIG             disabled veterans, but who did not actually     probation. Individuals were
                                                  control the companies.                          ordered to pay $5.5 million in
                                                                                                  restitution.
Note: The following lists define the program codes for legal actions and the abbreviations in the table.

Legal Actions Summary Program Codes
BL………..Business Loans
DL……….Disaster Loans
GC………Government Contracting and Section 8(a) Business Development
IA………..Internal Affairs
OT………Other

Joint Investigation Agency Acronyms
Defense Criminal Investigative Service (DCIS)
Department of Commerce Office of Inspector General (DOC/OIG)
Department of Energy Office of Inspector General (DOE/OIG)
Department of Health and Human Services Office of Inspector General (HHS/OIG)
Department of Homeland Security Homeland Security Investigations (DHS/HSI)
Department of Homeland Security Immigration and Customs Enforcement (DHS/ICE)
Department of Homeland Security Office of Inspector General (DHS/OIG)
Department of Justice Office of Inspector General (DOJ/OIG)
Department of Justice Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
Department of Justice Money Laundering & Asset Recovery Section (MLARS)
Department of State Office of Inspector General (DOS/OIG)
Department of Transportation Office of Inspector General (DOT/OIG)
Department of Treasury Inspector General for Tax Administration (TIGTA)
Department of Treasury Special Inspector General for the Troubled Asset Relief Program (SIGTARP)
Department of Veterans Affairs Office of Inspector General (VA/OIG)
Federal Bureau of Investigation (FBI)
Federal Deposit Insurance Corporation Office of Inspector General (FDIC/OIG)
Federal Housing Finance Agency Office of Inspector General (FHFA/OIG)
Federal Reserve Board Office of Inspector General (FRB/OIG)
General Services Administration Office of Inspector General (GSA/OIG)
Internal Revenue Service – Criminal Investigation (IRS/CI)
National Aeronautics and Space Administration Office of Inspector General (NASA/OIG)
State of California Employment Development Department (State of CA/EDD)



                                                              Spring 2022 Semiannual Report to Congress | 46
U.S. Small Business Administration | Office of Inspector General

United States Airforce Office of Special Investigations (AFOSI)
United States Army/Criminal Investigation Division (Army/CID)
United States Department of Agriculture Office of Inspector General (USDA/OIG)
United States Naval Criminal Investigative Service (NCIS)
United States Postal Inspection Service (USPIS)
United States Secret Service (USSS)




47 | Spring 2022 Semiannual Report to Congress
                           U.S. Small Business Administration | Office of Inspector General


Appendix F. Cosponsored and Other Activities
SBA’s authorization to cosponsor events requires OIG to report to Congress on the Administrator’s use of
that authority semiannually. The following list of activities was provided by the SBA Office of Strategic
Alliances.
 Name/Subject of Event             Name of Cosponsor(s)                                    Event             Date Fully
                                                                                           Location          Executed
 Woostapreneurs Forum              Massachusetts District Office, Worcester Area           Virtual           3/8/2022
                                   Chamber of Commerce
 Women’s Business Summit           Headquarters/Office of Women's Business                 Virtual           2/23/2022
                                   Ownership, Nasdaq Entrepreneurial Center
 Small Business Initiative         New York District Office, City of Newburgh              Newburgh, NY      2/11/2022
 Workshops and Webinars
 2022 Resource Partners Bi-        San Francisco District Office, California Association   Virtual and San   2/10/2022
 Annual Meetings                   for Microenterprise Opportunity                         Francisco
                                                                                           District Office
 Small Business Community          Headquarters/Office of Communications and               Virtual           2/8/2022
 Engagement Conversations          Public Liaison, Public Private Strategies Institute
 2022 Virtual Entrepreneurship     Vermont District Office, Vermont Small Business         Virtual           1/28/2022
 Day                               Development Center, Vermont Business Education
                                   Corporation, Vermont Career and Technical
                                   Student Organizations
 2022 Nevada Small Business        Nevada District Office, Access Community Capital        Las Vegas, NV     1/27/2022
 Awards
 National Small Business Week      Headquarters/Office of Communications and               Virtual           1/12/2022
 2022                              Public Liaison, SCORE Association, Visa USA Inc.,
                                   ADP Inc., Lockheed Martin Corp., Zebra
                                   Technologies, CenturyLink-Lumen Technologies
                                   Inc., Vistage Worldwide Inc., Fidelity National
                                   Information Services Inc., JPMorgan Chase Bank,
                                   Amazon.com Services, Constant Contact Inc.,
                                   Meta Platforms Inc. Facebook Inc., Block Inc.,
                                   Square Inc.
 National Small Business Week      Utah District Office, Mountain America Federal          Salt Lake City,   1/12/2022
 Awards Luncheon                   Credit Union, Utah Small Business Development           UT
                                   Center Network
 Lender Awards Breakfast           Utah District Office, Mountain America Federal          Salt Lake City,   1/12/2022
                                   Credit Union                                            UT
 Community Resources Lunch &       Arkansas District Office, Better Business Bureau of     Virtual           1/11/ 2022
 Learn with BBB and SBA            Arkansas Education Foundation Inc.
 Arkansas
 Government Procurement            North Dakota District Office, North Dakota Small        Virtual and       1/10/2022
 Training Series, FY 2022          Business Development Center, host of                    Statewide
                                   Procurement Technical Assistance Center
                                   University of North Dakota
 Small Business Digital Alliance   Headquarters/Office of the Administrator,               Virtual and SBA   1/4/2022
                                   Business Forward Inc.                                   Regional
                                                                                           Offices
 Small Business Saturday           Headquarters/Office of Communications and               Virtual and US    11/1/2021
                                   Public Liaison, American Express, WIPP                  Statewide
 Contracting, Financing and        Hawaii District Office, Hawaii Department of            Virtual and       10/27/2021
 Small Business Outreach           Transportation, Office of Civil Rights                  Hawaii
                                   Disadvantaged Business Enterprise, Minority             Statewide
                                   Business Development Center aka Honolulu
                                   Minority Business Center University of Hawaii
                                   Manoa, Shidler College of Business



                                                              Spring 2022 Semiannual Report to Congress | 48
U.S. Small Business Administration | Office of Inspector General

Massachusetts Small Business   Massachusetts District Office, Office of U.S.     Virtual   10/12/2021
B2B Contracting Matchmaker     Senator Elizabeth Warren, Massachusetts Small
                               Business Development Center, Massachusetts
                               Procurement Technical Assistance Center, Center
                               for Women and Enterprise, SCORE Boston Chapter




49 | Spring 2022 Semiannual Report to Congress
                      U.S. Small Business Administration | Office of Inspector General


Appendix G. External Peer Reviews
Section 5(a) of the IG Act requires OIGs to report peer review results in their Semiannual Reports to
Congress. The following information is provided in accordance with these requirements.

Audits Division
The Government Auditing Standards, or Yellow Book, issued by the Comptroller General of the United
States requires that audit organizations performing audits and attestation engagements in accordance
with the Yellow Book must have an external peer review performed by reviewers independent of the
audit organization being reviewed at least once every 3 years. OIG’s Audits Division was reviewed by the
National Science Foundation OIG for the period ending March 31, 2021. SBA OIG received a peer review
rating of pass.
Similarly, the Council of the Inspectors General on Integrity and Efficiency requires that organizations that
conduct inspections and evaluations under the Quality Standards for Inspection and Evaluation, or Blue
Book, must have an external peer review at least once every 3 years. During FY 2020, our Audits Division
underwent a Blue Book peer review conducted by the Department of Justice OIG. OIG generally met Blue
Book standards.
In addition, in FY 2022, our Audits Division reviewed the U.S. Department of Education OIG against the
Blue Book standards for the period ending September 30, 2021. Education OIG received a peer review
rating of pass.

Investigations Division
Section 6(e)(7) of the IG Act, Attorney General Guidelines for Offices of Inspector General with Statutory
Law Enforcement Authority, and the CIGIE Quality Standards for Investigations require external peer
reviews of OIG investigative functions be conducted every 3 years.
In September 2017, FDIC OIG reviewed our Investigations Division and issued a final report December 19,
2017. FDIC OIG found that the system of internal safeguards and management procedures for the
investigative function of OIG complied with the quality standards established by CIGIE and the applicable
Attorney General’s Guidelines. No recommendations were offered.




                                                   Spring 2022 Semiannual Report to Congress | 50
U.S. Small Business Administration | Office of Inspector General


Appendix H. Reporting Requirements in the Inspector General
Act of 1978, As Amended
 Section        Reporting Requirement                                  Location
 4(a)(2)        Review of legislation and regulations                  Other Significant OIG Activities
 5(a)(1)        Significant problems, abuses, and deficiencies         Throughout
 5(a)(2)        Recommendations with respect to significant            Significant Recommendations from This Reporting
                problems, abuses, and deficiencies                     Period
 5(a)(3)        Prior significant recommendations on which             Significant Recommendations from Prior Reporting
                corrective action has not been completed               Periods Without Final Action as of March 31, 2019
 5(a)(4)        Matters referred to prosecutive authorities            Legal Actions Summary
 5(a)(5)        Instances in which requested information was           N/A
                refused
 5(a)(6)        List of audit, inspection, and evaluation reports      Reports Issued; Reports with Questioned Costs
 5(a)(7)        Significant reports                                    Throughout
 5(a)(8)        Audit, inspection, and evaluation statistical tables   Statistical Highlights
 5(a)(9)        Audit, inspection, and evaluation reports with         Reports with Recommendations That Funds Be Put to
                recommendations that funds be put to better use        Better Use
 5(a)(10)       Audit, inspection, and evaluation reports without      Reports from Prior Periods with Overdue
                management decision, without comment within            Management Decisions; Reports from Prior Periods
                60 days, or with unimplemented                         with Open Recommendations as of March 31, 2019
                recommendations
 5(a)(11)       Revised management decisions                           Significant Revised Management Decisions
 5(a)(12)       Management decisions with which the Inspector          Significant Management Decisions with Which OIG
                General disagrees                                      Disagrees
 5(a)(13)       Information described under section 05(b) of the       Federal Financial Management Improvement Act
                Federal Financial Management Improvement Act
                of 1996
 5(a)(14)(16)   Peer review results                                    External Peer Reviews
 5(a)(17)(18)   Investigative statistical tables and supporting        Investigations Reporting Statistics
                metrics
 5(a)(19)       Investigations involving a senior government           Investigations Involving a Senior Government
                employee where allegations of misconduct were          Employee Where Misconduct Was Substantiated
                substantiated
 5(a)(20)       Whistleblower retaliation                              Whistleblower Retaliation Cases
 5(a)(21)       Attempts to interfere with the independence of         Instances of Interference
                OIG
 5(a)(22)       Each closed inspection, evaluation, and audit not      Investigations Involving a Senior Government
                disclosed to the public; each closed investigation     Employee that Is Closed and Not Disclosed to the
                involving a senior government employee not             Public
                disclosed to the public




51 | Spring 2022 Semiannual Report to Congress
                          U.S. Small Business Administration | Office of Inspector General

Make a Difference
To promote integrity, economy, and efficiency, we encourage you to report instances of fraud, waste, or
mismanagement to the OIG Hotline.*
Online: https://www.sba.gov/oig/hotline
Write or Visit:
U.S. Small Business Administration
Office of Inspector General
Investigations Division
409 Third Street, SW (5th Floor)
Washington, DC 20416

*In accordance with Sections 7 and 8L(b)(2)(B) of the Inspector General’s Act, confidentiality of a complainant’s personally
identifying information is mandatory, absent express consent by the complainant authorizing the release of such information.




                                                             Spring 2022 Semiannual Report to Congress | 52


File and source

File
SBA_OIG_Spring_2022_Semiannual_Report_to_Congress.pdf
Size
1,330,046 bytes
SHA-256
36cb3940bf6386029d06cce37d3fe9a9f11348bd21d706237975b73121d9007c
Our copy
SBA_OIG_Spring_2022_Semiannual_Report_to_Congress.pdf
Original
www.oversight.gov
Back to top