Small Business Administration:

The Commercial Marketing Representative Role Needs to Be Strategically Planned and Assessed

GAO-03-54: Published: Nov 1, 2002. Publicly Released: Nov 1, 2002.

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Subcontracting on federal contracts is a large and growing marketplace for small businesses. The Small Business Administration's (SBA) Commercial Marketing Representatives (CMRs) have long been considered to be key to fostering small businesses' participation in subcontracts. GAO was asked to assess the role that CMRs are playing in administering SBA's subcontracting assistance program.

CMRs are supposed to promote small business subcontracting in two primary ways. First, they review prime contractors' compliance with the requirements of their subcontracting plans--either through on-site visits to contractors or by simply reviewing their subcontractor activity reports. Second, they conduct various marketing activities, such as marketing small businesses to prime contractors. In recent years, however, additional duties placed on CMRs have often taken priority over these responsibilities. In fact, in fiscal year 2000, 87 percent of the CMRs had other substantial responsibilities. Moreover, workloads and prime contractor coverage now vary greatly between CMRs. Additionally, CMRs are relying more on "desk" reviews of subcontractors' activity to monitor compliance with subcontracting plans as opposed to on-site reviews. This is a concern to some SBA officials who believe that on-site reviews are more thorough, though others believe the desk review offers the potential for greater coverage. Declines in staffing and travel funds have contributed to the changing role of the CMR. With downsizing and retirements taking place and no staff assigned to replace lost personnel, the number of CMR full-time equivalents (FTEs) has decreased significantly and has resulted in workload imbalances. While there are concerns about the changing nature of the CMR role, SBA has not strategically planned for these changes or assessed their collective impact. Instead, it has implemented ad hoc measures to deal piecemeal with resource declines. Unless steps are taken to better evaluate and plan for the future of CMRs, SBA will continue to lack an understanding of their contributions to small business subcontracting.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Administrator of SBA should assess, evaluate, and plan the CMR role, including addressing such issues as the impact of assigning multiple roles to CMR's, the appropriate CMR role focus, the effectiveness of compliance-monitoring methods, and the impact of uneven CMR workloads and prime contractor coverage.

    Agency Affected: Small Business Administration

    Status: Closed - Not Implemented

    Comments: In a letter dated January 16, 2003, to Senator Lieberman and Representative Burton, the Administrator, Small Business Administration (SBA), wrote that SBA has already begun to assess, evaluate, and plan the role of the Commercial Marketing Representative (CMR) and expects to address all of GAO's specific concerns. SBA expanded coverage in 13 CFR 125.3, Subcontracting Assistance, by means of a Proposed Rule that was published on October 20, 2003. In June 2005, SBA stated that the regulation was published as a Final Rule, amending 13 CFR 125.3, on December 20, 2004. A Standard Operating Procedure (SOP 60 03 6) has also been revised. Further, SBA stated that it planned to begin a "comprehensive review" of the CMR mission, staffing and performance management in the next six months. The purpose of the review is to assess the impact of assigning multiple roles to CMRs, the appropriate CMR role focus, the effectiveness of compliance-monitoring methods, and the impact of uneven CMR workloads and prime contractor coverage. On July 12, 2005, SBA provided GAO an SBA status report (dated June 27, 2005)including a Final Rule. The Final Rule 13 CFR 125.3 addresses the issue. This recommendation is considered closed.

    Recommendation: The Administrator of SBA should develop specific outcome and impact measures for CMRs' effectiveness.

    Agency Affected: Small Business Administration

    Status: Closed - Not Implemented

    Comments: In a letter dated January 16, 2003, to Senator Lieberman and Representative Burton, the administrator, SBA, wrote that SBA has already begun to assess, evaluate, and plan the role of the CMR and expects to address all of GAO's specific concerns, including the need to develop additional outcome measures to demonstrate the success of the program. In June 2005 SBA stated that it uses a monthly report to identify SBA staff accomplishments. GAO requested a copy of the most recent monthly report pertaining to the subcontracting program and data on how many prime contractors have had increased compliance ratings as a result of CMR efforts. After over three years of trying to get an update on this recommendation and not receiving a credible response, we are closing out this recommendation as "closed but not implemented."

    Recommendation: The Administrator of SBA should clearly communicate the strategic plan and expectations for the CMR role to both SBA staff and small businesses.

    Agency Affected: Small Business Administration

    Status: Closed - Implemented

    Comments: In a letter dated January 16, 2003, to Senator Lieberman and Representative Burton, the Administrator, SBA, wrote that SBA has already begun to assess, evaluate, and plan the role of the CMR and expects to address all of GAO's specific concerns. This included communicating the strategic plan and expectations for the CMR role to both SBA and small businesses. SBA expanded coverage in 13 CFR 125.3 (Subcontracting Assistance), which can be viewed on GPO's web site at http://www.access.gpo.gov/su_docs/fedreg/a041220c.html. SBA also stated that SBA's 2003-2008 Strategic Plan is published on its web site at http://wwwsba.gov/strategic/strategisplan2003.pdf. Finally, SBA revised the SOP (60 03 6, Subcontracting Assistance Program) and it will be issued whenever SBA's gives final approval.

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