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GAO-11-548R: 

United States Government Accountability Office: 
Washington, DC 20548: 

June 15, 2011: 

The Honorable Mary L. Landrieu:
Chair:
The Honorable Olympia J. Snowe:
Ranking Member:
Committee on Small Business and Entrepreneurship:
United States Senate: 

The Honorable Sam Graves:
Chairman:
The Honorable Nydia M. Velázquez:
Ranking Member:
Committee on Small Business:
House of Representatives: 

Subject: Mentor-Protégé Programs Have Policies That Aim to Benefit 
Participants but Do Not Require Postagreement Tracking: 

A mentor-protégé program is an arrangement in which mentors-- 
businesses, typically experienced prime contractors--provide 
technical, managerial, and other business development assistance to 
eligible small businesses, or protégés. In return, the programs 
provide incentives for mentor participation, such as credit toward 
subcontracting goals, additional evaluation points toward the awarding 
of contracts, an annual award to the mentor providing the most 
effective developmental support to a protégé, and in some cases, cost 
reimbursement. Overall, mentor-protégé programs seek to enhance the 
ability of small businesses to compete more successfully for federal 
government contracts by furnishing them with assistance to improve 
their performance. We identified 13 federal agencies that currently 
have mentor-protégé programs including the Department of Homeland 
Security (DHS), Department of Defense (DOD), Department of Energy 
(DOE), Department of State (DOS), Environmental Protection Agency 
(EPA), Federal Aviation Administration (FAA), General Services 
Administration (GSA), Department of Health and Human Services (HHS), 
National Aeronautics and Space Administration (NASA), Small Business 
Administration (SBA), Department of the Treasury (Treasury), United 
States Agency for International Development (USAID), and the 
Department of Veterans Affairs (VA). 

The Small Business Jobs Act of 2010 required that we conduct a study 
on federal mentor-protégé programs to determine whether they are 
effectively supporting the goal of increasing small business 
participation in federal government contracting.[Footnote 1] This 
letter summarizes a March 2011 briefing we provided to your staff on 
the results of this work (see enclosure I for the briefing slides). It 
also includes updated information on the number of active mentor- 
protégé agreements reported by each agency as of March 2011 and 
additional audit work we conducted following the briefing on protégé 
postcompletion information. Our objectives were to (1) describe the 
policies and procedures for administering and monitoring federal 
mentor-protégé programs; (2) identify controls used to help ensure 
that mentor-protégé programs are beneficial to program participants 
and eligibility requirements are being met; and (3) determine if 
information is available on whether protégés have become able to 
compete for federal contracts without the assistance of a mentor. 

To address our objectives, we reviewed applicable regulations, polices 
and procedures, prior GAO and SBA Inspector General reports, and other 
agency guidance for administering and monitoring the mentor-protégé 
programs. In addition, we reviewed other documentary information on 
mentor-protégé agreements, mentor incentives, benefits to protégés, 
eligibility requirements, agency performance reviews, and measurements 
of the programs' performance. We interviewed agency officials and 
select industry-group representatives regarding controls and program 
oversight, as well as each agency's program objectives, types of 
mentor-protégé agreements, program requirements, and application 
review and approval processes. We also reviewed available information 
provided by agency officials on the extent to which protégés become 
able to compete for federal contracts without the assistance of a 
mentor, including any available information on additional protégé 
contracting and subcontracting opportunities. Finally, we interviewed 
agency officials and collected available information on what, if any, 
data is collected and maintained on protégés at the conclusion of the 
mentor-protégé relationship, as well as any implications and costs for 
the agencies associated with collecting and maintaining information on 
protégés after completion of the mentor-protégé program. We determined 
that the data we obtained from agency officials were reliable for the 
purposes of this report based on our audit objectives. 

In accordance with the statute, we focused on SBA and the 12 other 
federal agencies we identified as having a mentor-protégé program. As 
agreed with your offices, we focused on policies and procedures the 
agencies have put in place to administer and monitor the mentor-
protégé programs and controls to help ensure the programs are 
beneficial to participants. As agreed, we did not conduct testing on 
how well the program controls were operating because of the number of 
agencies with a mentor-protégé program and the associated time frame 
for completing our work to satisfy the mandate requirement. 

We conducted this performance audit from October 2010 through June 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

The first mentor-protégé program--the DOD Pilot Mentor-Protégé 
Program--was established by DOD as a pilot under the National Defense 
Authorization Act for Fiscal Year 1991. Since the pilot program was 
authorized, it has been continuously extended.[Footnote 2] The largest 
program--the SBA 8(a) Mentor-Protégé Program--was established in 1998. 
It is offered under SBA's 8(a) Business Development Program, which is 
one of the federal government's primary vehicles for developing small 
businesses owned and controlled by socially and economically 
disadvantaged individuals. Firms in SBA's 8(a) program receive SBA 
technical assistance and management training and may be eligible for 
contracts that federal agencies set aside for 8(a) firms. SBA's mentor-
protégé program serves as an additional developmental tool for 8(a) 
participants. Protégés in SBA's mentor-protégé program must also be 
participants in its 8(a) program. 

In general, the Office of Small and Disadvantaged Business Utilization 
(OSDBU) at each agency is responsible for mentor-protégé program 
management and administration, and some agencies also coordinate the 
program with their contracting offices.[Footnote 3] The one exception, 
however, is SBA's Mentor-Protégé Program, which is administered by its 
Office of Business Development through SBA's district offices and does 
not involve an OSDBU. At agencies other than SBA, mentors and protégés 
interested in becoming approved program participants submit an 
application to the OSDBU for review and approval. Upon receipt, the 
application is evaluated on the extent to which the mentor plans to 
provide developmental assistance to the protégé. In general, mentors 
and protégés are responsible for identifying and selecting each other 
prior to entering the program. 

As part of the process, mentors and protégés are required to jointly 
develop a tailored developmental assistance plan, which is set forth 
in a "mentor-protégé agreement" that is also submitted to OSDBU 
officials who, in turn, determine the agreement's compliance with 
specific agency requirements. The mentor-protégé agreement authorizes 
a broad array of developmental assistance, such as (a) training in the 
areas of production, quality control, manufacturing, engineering, and 
computer hardware and software; (b) assistance in obtaining production 
and accounting certifications needed to work on large federal 
government contracts; (c) contract administration; and (d) overall 
general business management skills and organizational management. 
Additionally, some agencies' programs allow mentors to provide loans 
and can award subcontracts on a noncompetitive basis. 

Generally, the responsible OSDBU officials periodically review the 
mentor-protégé agreement to help ensure that the terms of the 
agreement are being fulfilled, developmental assistance is being 
provided as agreed, and mentors and protégés comply with all agency 
requirements. The length of the mentor-protégé agreement varies by 
agency--usually from 1 to 3 years--and some agencies allow the 
agreement to be extended upon approval. However, some agencies have no 
fixed terms and, instead, limit the term of the agreement through 
negotiation or by tying the length of the agreement to the length of a 
contract. Participation in the mentor-protégé program also varies by 
agency. Figure 1 displays the number of mentor-protégé agreements 
across the federal government, as of March 31, 2011, which ranged from 
482 at SBA to 4 at EPA. 

Figure 1: Number of Mentor-Protégé Agreements by Federal Agency, as of 
March 2011: 

[Refer to PDF for image: vertical bar graph] 

Agency: SBA; 
Number of Mentor-Protégé Agreements: 482. 

Agency: DHS; 
Number of Mentor-Protégé Agreements: 220. 

Agency: DOE; 
Number of Mentor-Protégé Agreements: 120. 

Agency: DOD; 
Number of Mentor-Protégé Agreements: 101. 

Agency: DOS; 
Number of Mentor-Protégé Agreements: 86. 

Agency: GSA; 
Number of Mentor-Protégé Agreements: 65. 

Agency: TREAS; 
Number of Mentor-Protégé Agreements: 58. 

Agency: VA; 
Number of Mentor-Protégé Agreements: 24. 

Agency: NASA; 
Number of Mentor-Protégé Agreements: 12. 

Agency: FAA; 
Number of Mentor-Protégé Agreements: 10. 

Agency: HHS; 
Number of Mentor-Protégé Agreements: 9. 

Agency: USAID; 
Number of Mentor-Protégé Agreements: 6. 

Agency: EPA; 
Number of Mentor-Protégé Agreements: 4. 

Source: GAO compilation based on information reported by agencies with 
a mentor-protégé program. 

[End of figure] 

Similar Policies and Procedures Exist in Most Federal Mentor-Protégé 
Programs: 

All 13 federal agencies with mentor-protégé programs have established 
policies and procedures for administering and monitoring their 
programs. These policies and procedures are codified in regulatory 
guidance--such as the Federal Acquisition Regulation (FAR), agency 
supplemental-acquisition regulations, and program guidance--and are 
similar across most agencies. For example, all agencies have similar 
guidance that require the participants to develop a mentor-protégé 
agreement and to provide regular progress reports on the status of the 
mentoring agreement. Additionally, most agencies have similar guidance 
regarding the agency's noninvolvement in the partnering of mentors 
with protégés, as well as requirements for agencies to conduct 
periodic reviews. 

Despite similarities in program guidance, some differences exist. For 
example, different agencies have varying guidance regarding the length 
of mentor-protégé agreements and whether protégés are allowed to have 
more than one mentor.[Footnote 4] Some notable differences in the 
policies of 3 agencies bear specific mention: DOD, SBA, and FAA. 

* The DOD mentor-protégé program is the only mentor-protégé program 
mandated by law and receiving appropriated funding. DOD's program 
offers two major types of mentor-protégé agreements--credit and direct 
reimbursement--and although there are several different participating 
military services and defense agencies that administer their own 
mentor-protégé programs separately, they each share DOD regulations 
and policies.[Footnote 5] Along with DOE and FAA, DOD's mentor-protégé 
program is one of only three programs that offer cost reimbursement as 
an incentive for mentor participation. 

* SBA's mentor-protégé program permits a waiver of the affiliation 
rule for joint ventures between mentors and 8(a) protégés, allowing 
them to jointly pursue 8(a) contracts set aside for small businesses 
without the two firms being considered "affiliated" for purposes of 
SBA's small-business size standards. Additionally, the Small Business 
Jobs Act of 2010 granted SBA authority to establish new mentor-protégé 
programs for small businesses owned and controlled by service-disabled 
veterans and women and for HUBZone small businesses, modeled on SBA's 
current program for its 8(a) participants. 

* FAA's mentor-protégé program is the only mentor-protégé program that 
is not subject to the FAR and other related acquisition and 
procurement statutes and regulations.[Footnote 6] As previously noted, 
FAA's mentor-protégé program is one of only three programs that offer 
cost reimbursement as an incentive for mentor participation. 

Controls Exist to Help Ensure Participants Are Eligible and Benefit 
from Program Participation: 

Controls exist at all 13 federal agencies with mentor-protégé programs 
to help ensure that mentors and protégés meet eligibility criteria and 
benefit from participation in the program. Generally, a mentor may be 
either a large or small business, must be eligible for award of a 
government contract, and must be able to provide developmental 
assistance to enhance the capabilities of protégés. Agencies verify 
that these criteria are met by checking whether the mentor is on the 
"suspended" or "debarred" list and by requiring that mentors 
demonstrate their ability to provide the developmental assistance to 
the protégé upon entry into the program. Additionally, some agencies 
require their mentors to be current prime contractors or 
subcontractors with the agency. To qualify as a protégé under the 
program, all agencies require that the protégé be a small business 
(based on its primary North American Industrial Classification System 
code) and also be eligible to receive federal government contracts. 
While some agencies, such as SBA and VA, are specific about the types 
of small businesses that are eligible to participate in their program, 
most agencies accept various types of small businesses as protégés. 
[Footnote 7] 

Each of the mentor-protégé programs also have various reporting 
requirements that must be met by mentors and protégés during the 
course of the program which provide information on the protégé's 
growth, costs and expenditures, and completion of specific 
developmental activities. Generally, the agencies require that these 
reports be submitted annually or semiannually, either jointly by both 
the mentor and protégé or independently by the mentor only or the 
protégé only. Some agencies also require that the mentor and protégé 
provide a formal briefing (either interim or at the conclusion of the 
program) regarding any accomplishments or a "lessons-learned 
evaluation" upon completion of the program. 

To help ensure that protégés benefit from participation in the mentor- 
protégé program, most agencies conduct periodic annual reviews and 
compare the progress reported on by the mentor and protégé with the 
milestones established in the mentor-protégé agreement. By doing so, 
the agencies can gain assurance that the terms of the agreement are 
being fulfilled, developmental assistance is being provided as agreed, 
and protégés are benefiting from their participation in the program. 
Agencies may also conduct site visits or receive informal protégé 
reporting on any dissatisfaction with the developmental assistance 
being provided. If the protégé reports any such dissatisfaction, an 
agency generally has recourse to withhold approval of the continuation 
of the mentor-protégé agreement if it finds that the mentor has not 
provided the agreed-upon developmental assistance or if the assistance 
has not resulted in any material benefits to the protégé. However, 
according to agency officials, this rarely occurs. 

Moreover, as part of SBA's individual efforts to help ensure that its 
8(a) program is beneficial to participants and is not just a mechanism 
to enable participants (presumably large businesses) that would not 
otherwise qualify under the program to receive contracts, SBA recently 
added to its program controls. Specifically, SBA published a final 
rule on February 11, 2011, that revised its 8(a) program regulations, 
including those for its mentor-protégé program and joint ventures. 
Among other things, the revised regulations (1) add consequences for a 
mentor that does not provide its protégé the assistance required by 
their agreement, including stop-work orders and potential debarment; 
(2) require SBA's 8(a) participants in a joint venture to perform at 
least 40 percent of the work done by the joint venture, including work 
awarded under a mentor-protégé agreement; and (3) generally prohibit a 
non-8(a) participant to a joint venture, or its affiliates, from 
acting as a subcontractor on any 8(a) contracts. 

Most Federal Mentor-Protégé Programs Do Not Collect Postagreement 
Information on Protégé Success: 

Most federal mentor-protégé programs do not collect information on 
protégés after the conclusion of their mentor-protégé agreements; 
therefore, little information is available on the success of protégés 
after participating in the program.[Footnote 8] Of the 13 federal 
agencies we identified with mentor protégé programs, only 3 agencies-- 
DOD, NASA, and USAID--have policies in place to collect information on 
protégés after their mentor-protégé agreements have terminated. 
[Footnote 9] They each require protégés to submit a postcompletion 
report on their employment and revenue statistics annually for 2 years 
upon completion of the program. However, only DOD is required by 
statute to collect such information on protégés after they exit the 
program. Specifically, under DOD's program, protégés are required to 
report its progress annually for 2 years after exiting the program, 
including any successes that can be attributed to its participation in 
the program, such as in employment, annual revenue, and annual 
participation in DOD contracts[Footnote 10]. DOD is required to 
conduct annual performance reviews of the postcompletion information 
reported by protégés. 

Additionally, Congress required DOD to report annually on trends in 
the progress made in employment, revenues, and participation in DOD 
contracts of both protégés and former protégés.[Footnote 11] For 
example, in its annual report to Congress for fiscal year 2009, DOD 
noted that while the 61 former protégés providing postcompletion 
reports experienced a cumulative decrease in annual revenue and number 
of employees (which may have been the result of broader economic 
conditions), they experienced an average increase in number and dollar 
amount of DOD prime-contract and subcontract awards. They also 
experienced an average increase in the dollar amount of total federal 
subcontract awards following completion of program.[Footnote 12] 
Similarly, in its fiscal year 2008 annual report, DOD noted that 33 
former protégés experienced a cumulative increase in annual revenue 
and number of employees and an average dollar increase in DOD prime 
contracts and subcontracts since program completion.[Footnote 13] 
Congress required that DOD collect and report this information in 
order to help ensure that its mentor-protégé program is focused on a 
results-oriented approach to assessing program performance. DOD 
estimates that it has a total annual cost of about $51,000 related to 
the collection of postcompletion information reported to Congress, 
including one full-time procurement technician to request and maintain 
information on all protégé postcompletion reports, and a supervisor to 
review the data for abnormalities such as a significant change in 
revenue. 

As stated earlier, NASA and USAID both have policies in place to 
collect information on protégés after their mentor-protégé agreements 
have expired. However, because both NASA's and USAID's mentor-protégé 
programs are relatively new, information on the protégés' progress in 
the 2 years following completion of the program is not yet available. 
Officials from both agencies noted the importance of protégé 
postcompletion information in helping to determine whether the 
knowledge and skills obtained by the protégé during the mentoring 
agreement are sustainable beyond the term of the agreement. For 
example, USAID officials stated that information on the protégé's 
progress following completion of the program is important to them, 
particularly given its procurement timelines, because benefits 
resulting from the developmental assistance protégés obtain may not 
always be readily apparent during the life of the agreement. 

As noted previously, the remaining 10 federal agencies--DHS, DOE, DOS, 
EPA, FAA, GSA, HHS, SBA, Treasury, and VA--do not have policies and 
procedures in place to collect protégé postcompletion information. 
Most agency officials told us that while the information they 
currently collect on protégés during the course of a mentor-protégé 
agreement help to determine the overall success of their program, 
postcompletion information could also be useful.[Footnote 14] An 
official at one agency expressed concern that this information could 
be misleading because there is no assurance that a protégé's ability 
to compete and, ultimately, win federal contracts can be attributed to 
its participation in the mentor-protégé program. While changes in 
contracts awarded could reflect existing economic or industry 
conditions upon program completion, this is also true for data 
collecting during the mentor-protégé agreement as well. 

However, the potential benefits would have to be weighed against 
potential costs. Without having the experience of collecting and 
maintaining protégé postcompletion information, the officials were 
largely unable to provide estimates of the cost for implementing a 
process for collecting and maintaining the information. While some 
agency officials said that total costs associated with postcompletion 
reporting were unknown, they said they likely would include increased 
costs both in funds expended and manpower used. In addition, one 
official noted that the collection of postcompletion information for 
protégés could be complicated and time consuming. Conversely, a small 
number of agency officials believed the costs for collecting and 
maintaining protégé postcompletion information would be minimal or 
negligible, because they viewed the collection of postcompletion 
information as an extension of their current reporting processes that 
could be readily implemented with existing resources. 

As noted previously, most agencies have policies and reporting 
requirements to help ensure that protégés are benefiting from 
participation in their mentor-protégé programs. To determine overall 
success, the agencies collect information during the term of the 
agreement. However, postagreement data collection can provide 
additional information for agencies to use to ensure that their 
programs are benefiting the protégés as intended. 

Conclusions: 

While mentor-protégé programs have policies, procedures, and controls 
that aim to help ensure that participants benefit, information on the 
degree to which protégés are able to compete for contracts without the 
mentor is generally not available because most agencies do not collect 
information on protégé progress after the conclusion of their mentor- 
protégé agreements. Instead, most agencies rely on information 
collected during the term of the agreement to determine the 
effectiveness of the program. Specifically, of the 13 federal agencies 
with mentor-protégé programs, only 3--DOD, NASA, and USAID--have 
policies in place to collect information on protégé progress after the 
mentor-protégé agreements have terminated. While NASA and USAID have 
not yet collected data because their programs are relatively new, both 
have stated the importance of protégé postcompletion information in 
helping to determine whether the knowledge and skills obtained by the 
protégé during the mentoring agreement are sustainable beyond the term 
of the agreement. Moreover, Congress requires DOD to collect and 
report on postcompletion performance as one way to better ensure the 
effectiveness of the program. Although there is some uncertainty 
surrounding the total costs involved in collecting and maintaining 
postcompletion information, many agencies thought that, in addition to 
the information they currently collect on protégés during the course 
of the agreement, the postcompletion information could also be useful 
to the overall success of their programs. Without protégé 
postcompletion information, the agencies may miss the opportunity to 
obtain additional information that could be used to help them further 
assess the success of their programs and help ensure that small 
businesses are benefiting from participation in the programs as 
intended. 

Recommendations for Executive Action: 

To more fully evaluate the effectiveness of their mentor-protégé 
programs, we recommend that the OSDBU and Mentor-Protégé Program 
Directors of DHS, DOE, DOS, EPA, FAA, GSA, HHS, SBA, Treasury, and VA 
consider collecting and maintaining protégé postcompletion information. 

Agency Comments and Our Evaluation: 

We provided a draft of this letter and the attached briefing slides to 
each of the 13 agencies we identified as having a mentor-protégé 
program for their review and comment: DHS, DOD, DOE, DOS, EPA, FAA, 
GSA, HHS, NASA, SBA, Treasury, USAID, and VA. Five of the 13--DHS, 
DOE, DOS, Treasury, and VA--provided written comments, which are 
reprinted in enclosures II, III, IV, V, and VI respectively. In 
addition, GSA provided oral comments, while DOD, HHS, and SBA provided 
their comments electronically. Finally, EPA, FAA, NASA, and USAID 
stated that they had no comments on our draft letter. 

Our recommendation that the OSDBU and Mentor-Protégé Program Directors 
consider collecting and maintaining protégé postcompletion information 
was addressed to 10 of the 13 agencies in our review. Six of these 10--
DHS, DOE, GSA, HHS, Treasury, and VA--generally agreed with our 
recommendation: 

* DHS concurred with our recommendation, noting that it would consider 
following the DOD model by requiring protégés to report their progress 
annually for 2 years after exiting the program, including providing 
information on annual revenue, number of employees, and participation 
in DHS and other government contracts. Consistent with our 
recommendation, DHS stated that the potential benefits of collecting 
and maintaining this information would have to be weighed against 
potential costs. 

* DOE stated in its written comments that the department believes that 
protégé postcompletion information may be useful, along with other 
factors, in determining the success of the program and said that it 
will collect this information for protégés that are still small in 
their primary North American Industrial Classification System code 
when they graduate from the program. However, DOE commented that our 
conclusions focused only on postagreement data collection, which may 
lead a reader to assume that the collection of such data is the most 
important element of assessing a program's success. DOE stated that 
it, like other agencies, measures success for its mentor-protégé 
program through a semiannual review process in which it assesses 
various factors, including the number of contracts received by the 
protégé at both the prime and subcontract level, a protégé's profit 
margin, and the mentor's and protégé's overall satisfaction with the 
mentoring experience. We recognize that federal agencies use various 
performance measures to determine the success of their mentor-protégé 
programs. However, most agency officials told us that postcompletion 
information could also be useful. We clarified our discussion of our 
findings in this area in response to DOE's comments. 

* GSA and HHS generally concurred with our recommendation. 

* Treasury concurred with our recommendation, noting that it would 
implement a postagreement reporting requirement for firms exiting its 
mentor-protégé program beginning in fiscal year 2012. Treasury stated 
that protégé firms will be required to submit postagreement reports 24 
months after exiting the program and noted that approximately 30 
mentor-protégé agreements are due to expire in fiscal year 2012. 

* VA generally agreed with our conclusions and concurred with our 
recommendation, noting that its mentor-protégé program currently 
requires both the mentor and protégé to prepare an evaluation upon 
completion of the program. VA stated that it will add in the 
department's mentor-protégé guidebook a requirement to collect data 
from the protégé for 1 year after completing the program in order to 
evaluate the effectiveness of the program and the protégé's ability to 
compete on federal procurements without the assistance of a mentor. 

Although SBA stated in its comments that it agreed with a 
recommendation to collect and maintain information related to firms' 
activity following the completion of the mentor-protégé relationship, 
it did not agree with the recommendation as worded in our draft letter 
because it thought the recommendation would lead to the conclusion 
that all mentor-protégé programs have the same objective. SBA stated 
that its mentor-protégé program is a business-development tool used 
for the purpose of assisting the protégé in overcoming management and 
operational deficiencies that hinder its growth, development, and 
ultimate long-term success. SBA also stated that the ability to obtain 
contracts under its program is based on a separate joint-venture 
agreement under the mentor-protégé agreement and is only one form of 
assistance provided under the mentor-protégé agreement. SBA noted that 
mentor-protégé agreements based solely on facilitating access to 
government contracts are not allowed under its program. Our 
recommendation is not intended to imply that all mentor-protégé 
programs have the same objective, but rather is based on the fact that 
most programs currently do not collect information on protégés after 
the conclusion of the mentor-protégé agreement which could be used to 
help determine the overall success of these programs. We clarified the 
wording of our recommendation in response to SBA's comments. 

In addition, while DOS partially agreed with our recommendation and 
stated that it would initiate postprogram monitoring of its former 
protégé firms if such a policy were to be implemented, it also stated 
that it recommends against implementing increased reporting 
requirements at this time. It expressed concerns that postprogram data 
collection would increase the burden on all parties without adding 
significant value to the existing program. DOS also expressed concern 
about the impact that postcompletion reporting could have on the 
department, mentor firms, and protégé firms. In addition, DOS stated 
that participating firms would face additional reporting burdens that 
would be counterproductive and could discourage mentors from serving 
in its program. DOS also cited budgetary implications that the 
department would face, as it would have to increase staffing to 
collect and monitor the collection of protégé postcompletion 
information. As we note in the letter, agencies would have to weigh 
the impact of collecting and maintaining protégé postcompletion 
information against the potential benefits, which were acknowledged by 
most agencies we spoke with, including an agency that is already 
required to collect such information. While we understand DOS's 
concerns, as we note in the letter, without this type of information, 
agencies may miss the opportunity to obtain additional information 
that could be used to help them further assess the success of their 
programs and help ensure that small businesses are benefiting from 
participation in the programs as intended. Therefore, we continue to 
believe that DOS should consider collecting postprogram data. 

Finally, DOD, which is required to collect postprogram data on its 
mentor-protégé programs, told us that they concurred with our findings 
and suggested that the managers for the 13 mentor-protégé programs 
form an advisory council or working group to meet monthly and examine 
best practices and lessons learned to improve their agency programs 
and protégé growth. We encourage DOD's manager to pursue this idea 
with the other managers as a way to share information, best practices, 
and lessons learned. Given DOD's experience with postprogram data 
collection, it may be able to provide valuable insights to the other 
agencies about its experience. 

We are sending copies of this report to interested members of Congress 
and agency administrators at DHS, DOD, DOE, DOS, EPA, FAA, GSA, HHS, 
NASA, SBA, Treasury, USAID, and VA. In addition, this report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-8678 or shearw@gao.gov. Contact points for our 
Office of Congressional Relations and Public Affairs may be found on 
the last page of this report. Major contributors to this report were 
Marshall Hamlett, Assistant Director; Michelle Bowsky, Farah 
Angersola, Edwin Yuen, Tania Calhoun, and Jennifer Schwartz. 

Signed by: 
William B. Shear:
Director, Financial Markets and Community Investment: 

Enclosures: 

[End of section] 

Enclosure I: Briefing to the Committee on Small Business and 
Entrepreneurship, U.S. Senate and Committee on Small Business, House 
of Representatives: 

Federal Mentor-Protégé Programs: 

Briefing to Senate Small Business and Entrepreneurship Committee
and House Small Business Committee: 

March 2011: 

Introduction: 

The Small Business Jobs Act of 2010 (P.L. 111-240) requires that GAO 
conduct a study of federal mentor-protégé programs to determine 
whether they are effectively supporting the goal of increasing small 
business participation in federal government contracting. 

A mentor-protégé program is an arrangement in which mentors—-
businesses, typically experienced prime contractors-—provide 
technical, managerial, and other business development assistance to 
eligible small businesses, or protégés. Overall, the programs seek to 
enhance the ability of small businesses to compete more successfully 
for federal government contracts by furnishing them with assistance to 
improve their performance. 

In return, the programs provide incentives for mentor participation, 
such as credit towards subcontracting goals, additional evaluation 
points towards the awarding of contracts, annual mentor awards to the 
mentor providing the most effective developmental support to a 
protégé, and, in some cases, cost reimbursement. 

Thirteen federal agencies currently have mentor-protégé programs. 

Federal Mentor-Protégé Programs, by Year of Program Implementation: 

* Department of Defense (DOD), 1991; 
* Environmental Protection Agency (EPA), 1994; 
* Department of Energy (DOE), 1995; 
* National Aeronautics and Space Administration (NASA), 1995* (Program 
revamped in 2008); 
* Federal Aviation Administration (FAA), 1996; 
* Small Business Administration (SBA), 1998; 
* Department of Homeland Security (DHS), 2003; 
* Department of the Treasury (Treasury), 2003; 
* Department of State (DOS), 2005; 
* United States Agency for International Development (USAID), 2007; 
* General Services Administration (GSA), 2009; 
* Department of Health and Human Services (HHS), 2009; 
* Department of Veteran's Affairs (VA), 2010. 

Objectives: 

Our objectives for this review are to: 

* Describe the policies and procedures for administering and 
monitoring federal mentor-protégé programs; 

* Identify controls used to help ensure that mentor-protégé programs 
are beneficial to program participants and eligibility requirements 
are being met; and; 

* Determine if information is available on whether protégés have 
become able to compete for federal contracts without the assistance of 
a mentor. 

Scope and Methodology: 

To help address our objectives, we took the following actions: 

* To address objective 1, we reviewed applicable regulations, polices 
and procedures, and other agency guidance for administering and 
monitoring the mentor protégé programs. We interviewed agency 
officials regarding how the programs are administered and monitored, 
including each agency's program objectives, types of mentor-protégé 
agreements, program requirements, and application review and approval 
processes. 

* To address objective 2, we reviewed policies and procedures, agency 
guidance, prior GAO and inspector general reports, and other relevant 
documentary information on mentor-protégé agreements, mentor 
incentives, benefits to protégés, eligibility requirements, agency 
performance reviews, and measurements of theprograms' performance. We 
also interviewed agency officials and select industry group 
representatives regarding controls and program oversight. 

* To address objective 3, we reviewed available information on the 
extent to which protégés are able to compete for federal contracts 
without the assistance of a mentor, including available information on 
employment, revenue, and additional protégé contracting and 
subcontracting opportunities. We also interviewed agency officials on 
what, if any, information is maintained on protégés at the conclusion 
of the mentor-protégé agreement. 

* In accordance with the statute, we focused on SBA and the 12 other 
federal agencies we identified as having a mentor-protégé program. As 
agreed with your offices, we focused on policies and procedures the 
agencies put in place to administer and monitor the mentor-protégé 
programs and controls to help ensure the programs are beneficial to 
participants, but did not conduct testing on how well the program 
controls were operating. 

We conducted our work from October 2010 through March 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 
•	The first mentor-protégé program—-the Department of Defense (DOD) 
Pilot Mentor Protégé Program—-was established by DOD as a pilot under 
the National Defense Authorization Act for Fiscal Year 1991. Since the 
pilot program was authorized, it has been continuously extended). 
[Footnote 15] 

The next major program—-the Small Business Administration (SBA) 8(a) 
Mentor-Protégé Program-—was established in 1998. It is offered under 
the 8(a) Business Development Program, which SBA administers for small 
businesses owned and controlled by socially and economically 
disadvantaged individuals.[Footnote 16] 

Generally, the Office of Small and Disadvantaged Business Utilization 
(OSDBU) at each agency is responsible for mentor-protégé program 
management and administration.[Footnote 17] In addition, some agencies 
also coordinate their programs with the contracting offices. 

Mentors and protégés interested in becoming approved program 
participants must submit a joint application to the OSDBU for review 
and approval. The application is evaluated on the extent to which the 
mentor plans to provide developmental assistance to the protégé. 

In general, mentors and protégés are responsible for identifying and 
selecting each other prior to entering the program. 

Mentors and protégés are required to jointly develop a tailored 
developmental assistance plan which is set forth in a "mentor-protégé 
agreement" that is submitted to OSDBU officials who determine the 
agreement's compliance with specific agency requirements. 

The mentor-protégé agreement authorizes a broad array of developmental 
assistance, such as: 

- technology transfer, including training in the areas of production, 
quality control, manufacturing, engineering, computer hardware and 
software, and assistance in obtaining production and accounting 
certifications needed to work on large federal government contracts; 
and; 

- overall general business management skills, including financial and 
personnel management, marketing, and proposal writing; contract 
administration; and organizational management. 

Additionally, some programs allow mentors to provide loans and can 
award subcontracts on a noncompetitive basis. 

Generally, the responsible OSDBU officials periodically review the 
mentor-protégé agreement to ensure that the terms of the agreement are 
being fulfilled, developmental assistance is being provided as agreed, 
and mentors and protégés comply with all agency requirements. 

The length of the mentor-protégé agreement varies by agency—-usually 
from 1 to 3 years-—and some agencies may allow the agreement to be 
extended upon approval. However, some agencies have no fixed terms, 
and instead limit the term of the agreement through negotiation or by 
tying the length of the agreement to the length of a contract. 

Participation in the mentor-protégé program varies across agencies. 
For example, SBA, which has the largest program, has 480 current 
mentor-protégé agreements, whereas the Environmental Protection Agency 
(EPA) has 4 current agreements in place.
														
Figure: Number of Mentor Protégé Agreements Across the Federal 
Government, as of December 2010: 

[Refer to PDF for image: vertical bar graph] 

Agency: SBA; 
Agreements: 480. 

Agency: DHS; 
Agreements: 172. 

Agency: DOD; 
Agreements: 133. 

Agency: DOE; 
Agreements: 115. 

Agency: DOS; 
Agreements: 70. 

Agency: GSA; 
Agreements: 49. 

Agency: TREAS; 
Agreements: 43. 

Agency: VA; 
Agreements: 20. 

Agency: NASA; 
Agreements: 12. 

Agency: FAA; 
Agreements: 10. 

Agency: HHS; 
Agreements: 6. 

Agency: USAID; 
Agreements: 6. 

Agency: EPA
Agreements: 4. 

Agency: MP 

Source:	GAO DNS	compilation DOD	based DOE on information provided by 
agencies with a mentor-protégé program.	 

[End of figure] 
	
Figure: Illustrative Overview of Mentor Protégé Program: 

[Refer to PDF for image: illustration] 
						
Application and approval: 

(A) Mentor: Joint application to Agency OSDBU. 

(B) Protégé: Mentor protégé agreement to Agency OSDBU. 

Agency OSDBU approval/disapproval back to Mentor and/or Mentor protégé. 

OSDBU reviews joint application and mentor protégé, agreement for 
compliance with agency regulations. If either is disapproved, they are 
returned to the mentor/protégé for correction and resubmission. 

Mentoring relationship: 

(C) Developmental assistance: Mentor, protégé: mentor report; Protégé 
report; Joint report to Agency OSDBU. 

(D) Midpoint or annual reports submitted (report on progress of 
mentoring relationship and all developmental assistance 
provided/received). 

(E) Reports reviewed for adherence to the developmental assistance 
detailed in the	mentor-protégé agreement. Site visits may be 
conducted. OSDBU addresses problems/discrepancies.	 

(F1) Early termination by OSDBU, mentor, or protégé (due to unresolved 
problems). 

(F2) Mentoring relationship continues until end of agreed upon term 
(at which time a joint	or separate report should be submitted to	
OSDBU). OSDBU approves termination.	 

(F3) Mentor and protégé apply for an extension. OSDRU 
approves/disapproves of extension. 

Sources: GAO; Art Explosion.	 

[End of figure] 

Objective 1 - Policies and Procedures for Administering Mentor-Protégé 
Programs: 

All 13 federal agencies with mentor-protégé programs have established 
policies and procedures for administering and monitoring their 
programs. 

Each agency's policies and procedures consist of regulatory guidance 
such as the Federal Acquisition Regulation (FAR), agency supplemental 
acquisition regulations, and program guidance. In most cases, the 
program guidance is more directly linked to the overall administration 
and management of the mentor-protégé program. 

The program guidance is similar across most agencies. For example, all 
agencies have similar guidance regarding the agency's non-involvement 
in any partnering/teaming of mentors with protégés, the mentor-protégé 
application process, and approval of potential mentors and protégés 
for participation in the program. 

Additionally, the agencies each have similar program guidelines 
requiring the development of a mentor-protégé agreement, semi-annual 
or annual mentor and protégé reports, and periodic agency program 
reviews. 

Table: Regulatory and Program Guidance for Mentor-Protégé Programs: 
		
DHS: 
* 48 CFR Section 3502.219; 
* DHS Mentor-Protégé Program Guide 1.0—1.17. 

DOD: 
* 48 CFR Subpart 219.71; 
* 48 CFR Ch. 2--Defense Acquisition Regulations System, Appendix I.	 

DOE: 
* 48 CFR Subpart 919.70; 
* DOE Mentor Protégé Overview and Fact Sheet. 

DOS: 
* 48 CFR Section 619.202-70. 

FAA: 
* FAA Acquisition Management System 3.6.1; 
* FAA Mentor-Protégé Program Guide 1.0—1.17. 

EPA:	
* 48 CFR Section 1519.203. 

GSA: 
* 48 CFR Subpart 519.70; 
* GSA Mentor-Protégé Program Guidebook. 

HHS: 
* 48 CFR Section 352.219-70; 
* HHS Small Business Program Manual Chapter 14: Mentor Protégé Program. 

NASA: 
* 48 CFR Subpart 1819.72; 
* NASA Mentor-Protégé Program Guidebook; 
* NASA Mentor-Protégé Program Management Guidebook for Small Business 
Specialists. 

SBA: 
* 13 CFR Section 124.520; 
* SBA Mentor Protégé Overview and Fact Sheet. 

Treasury: 
* 48 CFR Section 1019.202-70. 

USAID: 
* 48 CFR Subpart 719.273; 
* The USAID Mentor-Protegé Program-—A Guide for Mentors and Protégés. 

VA: 
* 48 CFR Subpart 819.71; 
* VA Mentor-Protege Program Guidebook. 

[End of table] 

Differences in Policies and Procedures for Administering Mentor-
Protégé Programs: 

While the program guidance at most agencies is similar, there are some 
differences. For example, guidelines regarding the allowance of 
multiple mentors for each protégé and the term length of mentor-
protégé agreements differ across agencies (see slide 19). 

The following are additional differences in select mentor-protégé 
program guidance: 

DOD: 
This is the only program mandated by law and the only program that 
receives appropriated funding. It is one of only three programs which 
offer cost reimbursement as an incentive for mentor participation. It 
offers 2 major types of mentor-protégé agreements: 1) credit and 2) 
direct reimbursement. Several military services and defense agencies 
are involved in the program. They each administer their own program 
separately, but share DOD regulations and policies.[Footnote 18] 

SBA: 
The program permits a waiver of the affiliation rule for joint 
ventures between mentors and 8(a) protégés whereby the mentor may 
provide assistance to the protégé without causing the two firms to be 
considered "affiliated" for purposes of SBA's small business size 
standards. 

Additionally, the Small Business Jobs Act of 2010 gives SBA authority 
to establish new mentor-protégé programs for small businesses owned 
and controlled by service-disabled veterans and by women, and for
HUBZone small businesses, modeled on SBA's current program for
8(a) program participants. 

FAA: 
Unlike all other mentor-protégé programs, the program is not subject 
to the FAR and other related acquisition and procurement statutes and 
regulations.[Footnote 19] Additionally, it is one of only three 
programs which offer cost reimbursement as an incentive for mentor 
participation.[Footnote 20] 

Table: Differences in Requirements for Multiple Mentors and Term of 
Mentor Protégé Agreements: 

Agency: DHS; 
Multiple Mentors Allowed (within agency): Yes; 
Term of Mentor-Protégé Agreements: 3 years. 

Agency: DOD; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 3 years. 

Agency: DOE; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 2 years. 

Agency: DOS; 
Multiple Mentors Allowed (within agency): Yes; 
Term of Mentor-Protégé Agreements: No fixed term. 

Agency: FAA; 
Multiple Mentors Allowed (within agency): Yes; 
Term of Mentor-Protégé Agreements: No fixed term. 

Agency: EPA; 
Multiple Mentors Allowed (within agency): Yes; 
Term of Mentor-Protégé Agreements: No fixed term. 

Agency: GSA; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: No fixed term. 

Agency: HHS; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 3 years. 

Agency: NASA; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 3 years. 

Agency: SBA; 
Multiple Mentors Allowed (within agency): Yes (with limitations); 
Term of Mentor-Protégé Agreements: 1 year. 

Agency: Treasury; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 1 year. 

Agency: USAID; 
Multiple Mentors Allowed (within agency): Yes; 
Term of Mentor-Protégé Agreements: 3 years. 

Agency: VA; 
Multiple Mentors Allowed (within agency): No; 
Term of Mentor-Protégé Agreements: 3 years. 

[End of table] 

Objective 2: Controls to Help Ensure Eligibility and Benefits to 
Protégés:	 

Controls exist at all 13 agencies with mentor-protégé programs to help 
ensure that mentors and protégés meet eligibility criteria and 
protégés benefit from participation in the program. 

Generally, the first control encountered by prospective mentors and 
protégés is the verification of eligibility to participate in the 
mentor-protégé program. 

The most common eligibility criterion for both mentors and protégés is 
an eligibility to receive government contracts. Agencies verify that 
this criterion is met by checking whether the mentor and protégé are 
on the "suspended" or "debarred" lists. 

Size restrictions for protégés are verified by checking the protégé 
firms' primary North American Industry Classification System (NAICS) 
code, which is used to classify businesses according to type of 
economic activity. 

Moreover, all agencies require that only certain types of small 
business are eligible to participate in the program as protégés (see 
slide 23). 

Table: Eligibility Requirements for Mentors: 

Agency: DHS; 
Business Size (Large/Small): L; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Empty]. 

Agency: DOD; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Check]. 

Agency: DOE; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: 

Agency: DOS; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Empty]. 

Agency: FAA; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Empty]. 

Agency: EPA; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Check]. 

Agency: GSA; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check] (for Large); 
Other Qualifications: [Check]. 

Agency: HHS; 
Business Size (Large/Small): 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Check]. 

Agency: NASA; 
Business Size (Large/Small): 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Check]. 

Agency: SBA; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check] (with limitations); 
Other Qualifications: [Check]. 

Agency: Treasury; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Empty]. 

Agency: USAID; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: [Empty]; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Empty]. 

Agency: VA; 
Business Size (Large/Small): L/S; 
Eligible for Federal Contracts: [Check]; 
Ability to Help Protégé: [Check]; 
Current Prime or Sub Contractor: Prime or Sub; 
Multiple Protege Allowed: [Check]; 
Other Qualifications: [Check]. 

[End of table] 

Table: Eligibility Requirements for Protégés: 

Agency: OHS; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: DOD; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes (with exceptions); 
Other Qualifications: 

Agency: DOE; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: DOS; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes; 
Protégé Self-Certify to Mentors (Yes/No): Yes (with exceptions); 
Other Qualifications: 

Agency: FAA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: EPA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: GSA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes (with exceptions); 
Other Qualifications: 

Agency: MIS; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: NASA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes (with exceptions); 
Other Qualifications: 

Agency: SBA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes (with 
limitations); 
Protégé Self-Certify to Mentors (Yes/No): No; 
Other Qualifications: 

Agency: Treasury; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes (with exceptions); 
Other Qualifications: 

Agency: USAID; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): Yes; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

Agency: VA; 
Small by industrial code standard: [Check]; 
Eligible for Government Contracts: [Check]; 
Multiple Mentors Allowed within agency (Yes/No): No; 
Protégé Self-Certify to Mentors (Yes/No): Yes; 
Other Qualifications: 

[End of table] 

Table: Types of Small Businesses Accepted as Protégés: 

Agency: DHS; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 

Agency: DOD; 
Small Business: 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Empty]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Check]. 

Agency: DOE; 
Small Business: 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Empty]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Check]; 
Other Qualifying Categories: 8(a). 

Agency: DOS; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 

Agency: FAA; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Empty]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Empty]; 
HBCU and Minority Institutions: [Check]; 
Other Qualifying Categories: [Check]. 

Agency: EPA; 
Small Business: 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Empty]; 
Service-Disabled Veteran-Owned: [Empty]; 
HUBZone: [Empty];  
HBCU and Minority Institutions: [Check]; 
Other Qualifying Categories: [Empty]. 

Agency: GSA; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 

Agency: HHS; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 

Agency: NASA; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Check]; 
Other Qualifying Categories: [Check]. 

Agency: SBA; 
Small Business: [Empty]; 
Small Disadvantaged Business: [Empty]; 
Women-Owned: [Empty]; 
Veteran-Owned: [Empty]; 
Service-Disabled Veteran-Owned: [Empty]; 
HUBZone: [Empty]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: 8(a). 

Agency: Treasury; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 

Agency: USAID; 
Small Business: [Check]; 
Small Disadvantaged Business: [Check]; 
Women-Owned: [Check]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Check]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Check]. 

Agency: VA; 
Small Business: [Empty]; 
Small Disadvantaged Business: [Empty]; 
Women-Owned: [Empty]; 
Veteran-Owned: [Check]; 
Service-Disabled Veteran-Owned: [Check]; 
HUBZone: [Empty]; 
HBCU and Minority Institutions: [Empty]; 
Other Qualifying Categories: [Empty]. 
								
[End of table] 

Controls to Help Ensure Benefit to Participants: 

For each mentor-protégé program, another control once eligibility has 
been established is the interim reports that are required of mentors 
and protégés. 

Generally, the agencies require that these reports be submitted either 
annually or semiannually, and either by the mentor and protégé jointly 
or independently. In a relatively few instances, some agencies will 
also require that the mentor and protégé provide a formal briefing 
(either interim or at the conclusion of the program) regarding any 
accomplishments. 

Some agencies (7 of 13) require that the mentor and protégé report 
semiannually, while another five agencies require that they report 
annually. Most of the agencies (9 of 13) also require that a report be 
submitted upon completion of the program, such as a "lessons learned" 
evaluation. 

As part of the required interim reports for mentors and protégés, the 
agencies generally request data on protégé growth (such as in numbers 
of contracts, finances, or employees), costs and expenditures, and 
accomplishment of specific developmental activities. 

Some agencies provide sample reports or templates for these reports on 
their website. 

Although these reporting requirements exist, we found that some 
mentors and protégés have not yet submitted the required reports 
because the mentor-protégé programs were recently implemented and the 
mentor-protégé agreements have not been in place long enough to meet 
the requirement for an interim report. To date, HHS and VA have not 
yet received the required reports from mentors and protégés in their 
program because their programs were implemented in 2009 and 2010, 
respectively. 

Table: Mentor and Protégé Reporting Requirements: 

Agency: DHS; 
Intermediate Reviews and Reports: 18-month; 
Intermediate Participant Briefing (Yes/No): Yes; 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: DOD; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): 
Post-Agreement Review: 2-year. 

Agency: DOE; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: DOS; 
Intermediate Reviews and Reports: Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: FAA; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): Yes; 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: EPA; 
Intermediate Reviews and Reports: Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): 
Post-Agreement Review: [Empty]. 

Agency: GSA; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): Yes; 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: HHS; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): Yes; 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: NASA; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): 
Post-Agreement Review: 2-year. 

Agency: SBA; 
Intermediate Reviews and Reports: Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): 
Post-Agreement Review: [Empty]. 

Agency: Treasury; 
Intermediate Reviews and Reports: Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 

Agency: USAID; 
Intermediate Reviews and Reports: Annual; 
Intermediate Participant Briefing (Yes/No): 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: 2-year. 

Agency: VA; 
Intermediate Reviews and Reports: Semi-Annual; 
Intermediate Participant Briefing (Yes/No): Yes; 
Reports/Presentation at Conclusion (Yes/No): Yes; 
Post-Agreement Review: [Empty]. 
				
[End of table] 

Controls to Help Ensure Benefit to Participants:	 

The mentor-protégé agreement itself also serves as a program control 
within all agencies. The agencies attempt to ensure benefits to 
protégés by requiring mentors to include descriptions, plans and 
schedules for developmental assistance in the agreement that is 
submitted to the agency for approval. Agencies will then compare the 
reported progress with the published schedule during the periodic 
reviews of the agreement. 

As an oversight measure, agency officials may also conduct site visits 
to help ensure that protégés are receiving the benefits agreed to in 
the mentor-protégé agreement. 

In addition, some agencies rely upon protégés to specifically report 
to agency officials if the terms of the mentor-protégé agreement are 
not being fulfilled or if they are dissatisfied with the developmental 
assistance being provided by the mentor. 

As an additional program control, each agency periodically conducts 
annual performance reviews of the mentor-protégé relationship to help 
ensure that the terms of the mentor-protégé agreement are being 
fulfilled and the developmental assistance is being provided as agreed. 

Generally, an agency may withhold approval of the continuation of a 
mentor-protégé agreement if it finds that the mentor has not provided 
the assistance set forth in the agreement or that the assistance has 
not resulted in any material benefits to the protégé, as determined by 
the agency. However, according to agency officials, this occurs very 
infrequently. 

Further, as part of SBA's efforts to help ensure that program benefits 
are provided to intended recipients and are not just a mechanism to 
enable participants that would not otherwise qualify under its 8(a) 
program to receive contracts, on February 11, 2011, SBA published a 
final rule revising its 8(a) program regulations, including those for 
its mentor-protégé program[Footnote 21] and joint ventures. 

Among other things, the revised regulations add consequences for a 
mentor that does not provide its protégé the assistance required by 
their agreement, including stop-work orders and potential debarment; 
require SBA's 8(a) participants to a joint venture to perform at least 
40 percent of the work done by the joint venture, including work 
awarded under a mentor/protégé agreement; and generally prohibit a non-
8(a) participant to a joint venture, or its affiliates, from acting as 
a subcontractor on any 8(a) contracts. 

Objective 3: Information on Protégés After Conclusion of Mentor-
Protégé Program: 

Information on whether protégés have become able to compete for 
federal contracts without the assistance of a mentor is generally not 
available because most agencies do not maintain information on 
protégés after the conclusion of the mentor-protégé program. 

Most agency officials told us that information is collected and 
maintained on the protégé only while the protégé is participating in 
the program. 

For example, most agencies collect information on the increase in 
number, dollar value, and percentage of contacts/subcontracts awarded 
to the protégés during the mentoring agreement. 

Some agencies also collect information on any increase in protégé 
subcontracting opportunities in areas where the protégé had not 
traditionally performed, thus indicating that the protégé is expanding 
its field of expertise. 

Additionally, some agencies have established policies and procedures 
that utilize information collected on the protégés progress during the 
mentoring agreement to determine the overall success of their mentor-
protégé programs. 

Of the 13 agencies with mentor protégé programs, only 3 agencies—-DOD, 
NASA and USAID—-currently have policies and procedures in place to 
collect information on protégés after they complete the mentor-protégé 
program.[Footnote 22] 

DOD, NASA and USAID require that protégés submit a post-completion 
report on their employment and revenue statistics for each of the 2 
years following conclusion of the program. 

In addition, DOD and NASA require that the post-completion reports 
include information on all within-agency and other prime contract and 
subcontract awards to protégés, and subcontract awards from protégés, 
such as: 

* Number/dollar of prime contract awards to protégé;
* Number/dollar of subcontract awards to protégé from mentor;
* Number/dollar of subcontract awards to protégé from other sources 
(other than mentor);
* Number/dollar of subcontract awards from protégé to mentor; and; 
* Number/dollar of subcontract awards from protégé to other sources 
(other than mentor). 

DOD's requirement for collecting and maintaining information on the 
protégé after conclusion of the mentor-protégé program derives from 
amendments to the program in the National Defense Authorization Act 
for Fiscal Year 2000.[Footnote 23] 

The statute requires that protégés report to DOD their progress in 
each of the 2 years following the completion of the program. 

Specifically, protégés are required to report on their progress made 
since exiting the program, as well as any successes that have been 
achieved that can be attributed to the program, such as employment, 
annual revenue, and annual participation in DOD contracts. 

Additionally, to ensure that the DOD mentor protégé program is focused 
on a results-oriented approach to assessing program performance, 
Congress required DOD to report annually on trends in the progress 
made in employment, revenues, and participation in DOD contracts of 
protégés and former protégés. 

DOD is also required to conduct annual performance reviews to verify 
whether the mentors and protégés accurately reported progress and to 
determine that all costs reimbursed to mentors were reasonably 
incurred in accordance with the statute and applicable regulations. 

According to its fiscal year 2009 annual report to Congress, DOD 
reported that protégés experienced an average increase in the number 
of DOD prime contract and subcontract awards, and an average dollar 
increase of all subcontract awards, but a cumulative decrease in 
revenue and number of employees in the 2 years following completion of 
the program.[Footnote 24] 

NASA and USAID are not required to maintain information on protégés 
following the completion of the mentor-protégé program. Specifically, 
with the exception of DOD, none of the other agencies that have a 
mentor-protégé program are required to maintain information on 
protégés following completion of the program. 

However, both NASA and USAID have established policies and procedures 
requiring that the protégé submit information on employment and 
revenue for each of the 2 years following completion of the program. 

Each agency's reports are due one month after the end of the first and 
second year following completion of the program. 

According to officials, because the USAID and NASA mentor-protégé 
programs began operating in 2007 and 2008, respectively, protégés have 
not yet submitted post-completion reports. As discussed earlier, both 
USAID and NASA mentor-protégé agreements have a 3-year term. 

On the Web: 

Web site: [hyperlink, http://www.gao.gov/] 

Contact: 

Chuck Young, Managing Director, Public Affairs, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: 

Copyright: 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. The published product may be 
reproduced and distributed in its entirety without further permission 
from GAO. However, because this work may contain copyrighted images or 
other material, permission from the copyright holder may be necessary 
if you wish to reproduce this material separately. 

[End of enclosure] 

Enclosure II: Comments from the Department of Homeland Security: 

Homeland Security: 

June 1, 2011: 

William Shear: 
Director, Financial Markets & Community Investment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO 11-5488, Mentor-Protege Programs Have Policies 
That Aim to Benefit Participants but Do Not Require Post-Agreement 
Tracking: 

Dear Mr. Shear: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DI IS) appreciates 
the U.S. Government Accountability Office's (GAO's) work in planning 
and conducting its review. 

The Department is pleased to note GAO's positive acknowledgment of 
many DHS Office of Small and Disadvantaged Business Utilization 
efforts related to the mentor-protege program. such as the controls 
that have been developed to help ensure that mentors and proteges meet 
eligibility criteria and proteges benefit from participation in the 
program. DHS is proud to have the second highest number of mentor-
protégé agreements of 13 agencies across the Federal Government and is 
committed to ensuring its program effectively supports the goal of 
increasing small business participation in government contracting. 

GAO recommended that DHS "consider collecting and maintaining protege 
post-completion information" to more fully evaluate the effectiveness 
of its mentor-protege program and the ability of small businesses to 
effectively compete for government contracts. DHS concurs with this 
recommendation. DHS will consider following the Department of Defense 
model by requiring proteges to report their progress annually for 2 
years after exiting the program, including information on annual 
revenue, number of employees, and participation in DHS and other 
federal contracts. However, as GAO acknowledges in its report, the 
potential benefits of doing this will have to be weighed against 
potential costs. 

Again, thank you for the opportunity to review and comment on this 
draft report. We look forward to working with you on future Homeland 
Security issues. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of enclosure] 

Enclosure III: Comments from the Department of Energy: 

Department of Energy: 
Washington, DC 20585: 

June 3, 2011: 

Mr. William Shear: 
Director, Financial Markets and Community Investments: 
United States Government Accountability Office: 
441 G. Street, N.W. 
Washington, RC, 20548: 

Dear Mr. Shear: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) draft report on the Department of 
Energy's (DOE or Department), Federal Mentor-Protégé
Programs (GAO-11-548R). 

DOE's concern is that the GAO conclusion focuses only on post-
agreement data collection, leading the reader to assume that this 
objective is the most important to having a successful Mentor-Protégé 
Program. The conclusion of this report states (beginning at the bottom 
of page 12): "However, without post-agreement data collection, the 
ability of these agencies to ensure that their programs are benefiting 
the protégés as intended is limited." This implies that the . success 
of a mentor-protege program solely depends on the collection of post 
mentor-protégé agreement information on proteges. 

The report clearly identifies three objectives: 

(1) Describe the policies and procedures for administering and 
monitoring Federal mentor-protégé programs; 

(2) Identify controls used to help ensure that mentor-protégé programs 
are beneficial to program participants and eligibility requirements 
are being met; and; 

(3) Determine if information is available on whether protégés have 
become able to compete for Federal contracts without the assistance of 
a mentor. 

DOE, like other agencies, established objectives for its mentor-
protégé program and measures success by the achievement of these 
objectives through a semi-annual review process. The Department's 
review process assesses: 

* The number of contracts received by the protege at both the prime 
and subcontract level; 

* The additional employees hired; 

* An increase in revenue received; 

* A protégé's profit margin; and; 

* The mentor's and protégé's overall satisfaction with the mentoring 
experience. 

For DOE, after a 2-year term with an average of a 1 to 2-year 
extension as a protege, many of the proteges have grown to an extent 
that they are no longer classified as a small business in their 
primary North American Industrial Classification System (NAICS) code, 
as they have exceeded the size standard limitation.	In the end, 
becoming a large business is a goal of most small businesses, and 
certainly one of the best measures of success. 

The Department believes that post-agreement information may be useful, 
along with other factors, in determining the success of the program. 
Therefore, we will collect it for proteges that are still small in 
their primary NAICSs code when they graduate from the program. We look 
forward to working with your team on future engagements. 

Sincerely, 

Signed by: 

William	J. Valdez: 
Acting Director: 
Office of Small and Disadvantaged Business Utilization: 
Office of Economic Impact and Diversity: 

Attachment: 

[End of enclosure] 

Enclosure IV: Comments from the Department of State: 

United States Department of State: 
Chief Financial Officer: 
Washington, DC 20520: 

June 2, 2011: 

Ms. Jacquelyn Williams-Bridgers: 
Managing Director: 
International Affairs and Trade: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548-0001: 

Dear Ms. Williams-Bridgers: 

We appreciate the opportunity to review your draft report,
"Mentor-Protégé Programs Have Policies That Aim to Benefit 
Participants but Do Not Require Post-Agreement Tracking," GAO Job Code 
250602. 

The enclosed Department of State comments are provided for 
incorporation with this letter as an appendix to the final report. 

If you have any questions concerning this response, please contact
Shapleigh Drisko, Director, Bureau of Administration. Office of Small 
and Disadvantaged Business Utilization at (703) 875-6823. 

Sincerely, 

Signed by: 

James L. Millette: 

cc: GAO — William B. Shear: 
A - Will Moser: 
State/OIG - Evelyn Klemstine: 

[End of letter] 

Department of State Comments on GAO Draft Report: 

Mentor-Protégé Programs Have Policies That Aim to Benefit Participants 
but Do Not Require Post-Agreement Tracking (GAO-11-548R, GAO Code 
250602): 

Thank you for the opportunity for commenting on your report. The 
Department partially agrees with GAO's recommendation. The Mentor 
protégé program is a successful tool that allows the Department to 
expand the capabilities and foster the growth of American small 
business contractors. We reviewed your findings and recommendations 
and are concerned about the program implications that post-completion 
reporting for Mentor-Protégé programs will have on the Department, the 
protégé firms, and the mentor firms. 

If the policy is implemented, the Department would initiate post-
program monitoring of its former protégé firms. However, the 
Department recommends against implementing increased reporting 
requirements as it would increase the burden on all parties without 
adding significant value to the existing program. First, it would 
place additional reporting burdens on participating firms which would 
be counter productive. The OMB specifically asks agencies to find ways 
of reducing cost and time burden placed on the public, but this 
initiative goes in the opposite direction. Experience tells us that 
large firms are sometimes ambivalent about participation in the 
program and additional reporting requirements could be enough to 
discourage them from serving as mentors in the program. 

Staffing to manage this program in the Department would consist of one 
or more technicians and supervisory capacity to monitor their work. 
This would also have labor and non-labor budgetary implications for 
the Department. 

Given the current success of the program, tentative hold on large firm 
participation, and possible budget implications in the Department, we 
feel that the addition of this reporting requirement would be ill-
advised at this time. 

[End of enclosure] 

Enclosure V: Comments from the Department of the Treasury: 

Department of the Treasury: 

Comments on Proposed Correspondence and GAO-11-548R Federal Mentor 
Protégé Programs: 

The Department of the Treasury, Office of Small and Disadvantaged 
Business Utilization, has reviewed the proposed correspondence and 
briefing slides entitled "Mentor-Protégé Programs Have Policies That 
Aim to Benefit Participants but Do Not Require Post-Agreement 
Tracking." 

The Department of the Treasury is in the process of revising its 
Mentor-Protégé Program policies and procedures and will include the 
requirement for post-agreement reporting by the Protégé firms as 
recommended in GAO-11-548R, Federal Mentor-Protégé Programs. The post-
agreement reporting requirement will be implemented for firms exiting 
the Mentor-Protégé Program beginning in Fiscal Year 2012. Protégé 
firms will be required to submit post-agreement reports 24 months 
after exiting the program. Approximately 30 Mentor-Protégé agreements 
are due to expire in Fiscal Year 2012. Participants in the Mentor-
Protégé Program will be informed in writing of the new reporting 
requirement, including reporting guidelines and due dates. 

In the interim, the Department of the Treasury will survey existing 
Mentor-Protege teams to assess Program effectiveness and to assist in 
making quality improvements; and prepare brief case study summaries of 
each of the dyads, and/or an overall retrospective statistical summary 
of Treasury's Mentor—Protégé program. The resulting information will 
be included in the annual OMWI report to Congress. 

[End of enclosure] 

Enclosure VI: Comments from the Department of Veterans Affairs: 

Department of Veterans Affairs: 
Washington DC 20420: 

May 31, 2011: 

William B. Shear: 
Director, Financial Markets and Community Investment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Shear: 

The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, Mentor-Protégé Programs 
Have Policies That Aim to Benefit Participants but Do Not Require Post-
Agreement Tracking (GAO-11-548R) and generally agrees with GAO's 
conclusions and concurs with GAO's recommendation. 

The enclosure specifically addresses GAO's recommendation on the draft 
report. VA appreciates the opportunity to comment on you draft report. 

Sincerely, 

Signed by: 

John R. Gingrich: 
Chief of Staff: 

Enclosure: 

[End of letter] 

Enclosure: 

Department of Veterans Affairs (VA) Response to Government 
Accountability Office (GAO) Draft Report: 

Mentor-Protégé Programs Have Policies That Aim to Benefit Participants 
but Do Not Require Post-Agreement Tracking (GAO-11-548R): 

GAO recommendation: To more fully evaluate the effectiveness of their 
mentor-protégé programs and the ability of small businesses to 
effectively compete for government contracts, we recommend that the 
OSDBU and Mentor-Protégé Program Directors of DHS, DOE, DOS, EPA, EPA, 
FAA, GSA, HHS, SBA, Treasury, and VA consider collecting and 
maintaining protégé post-completion information. 

VA response: Concur. Currently VA's Mentor-Protégé Program (MPP) 
requires the mentor and protégé to prepare an evaluation of VA's MPP 
upon completion of the program. Additionally, VA will add in the VA 
Mentor-Protégé Guidebook a requirement to collect data from the 
protégé for one year after completing VA's MPP in order to evaluate 
the effectiveness of the program and the protégé's ability to compete on
Federal procurements without the assistance of a mentor. 

[End of enclosure] 

Footnotes: 

[1] Pub. L. No. 111-240, § 1345, 124 Stat. 2504, 2546 (2010). 

[2] The Department of Defense and Full-Year Continuing Appropriations 
Act, 2011, extended the program until September 30, 2011, for approval 
of new agreements and until September 30, 2014, for only reimbursement 
of incurred costs or credit toward attainment of a subcontracting goal. 

[3] Although some agencies may refer to their offices as the Office of 
Small Business Programs or Small Business Development Office, for 
simplicity we use the term OSDBU for all agencies in this report. 

[4] All agencies allow mentors to have multiple protégés, while most 
agencies do not allow protégés to have more than one mentor. 

[5] In 2003, the program transitioned from the Office of the Secretary 
of Defense, OSDBU level to the military services and defense agencies. 
Services and agencies currently involved include: Army, Navy, Air 
Force, U.S. Special Operations Command, Joint Ground Robotics 
Enterprise, National Geospatial Intelligence Agency, National Security 
Agency, Missile Defense Agency, Defense Contract Management Agency, 
and Defense Logistics Agency (no current mentor-protégé agreements). 
Although it had prior involvement, the Defense Information Systems 
Agency is not currently involved in the program. 

[6] The Fiscal Year 1996 Department of Transportation Appropriations 
Act directed FAA to develop its own acquisition-management system 
outside of FAR. It developed the FAA Acquisition System Toolset, 
including the acquisition-management system that consists of 
acquisition management policy and guidance specific to FAA. 

[7] SBA's mentor-protégé program is limited to participants in the 
8(a) program, and VA's mentor-protégé program is limited to small 
businesses owned by veterans and service-disabled veterans. Most 
agencies accept various types of small businesses as protégés in their 
mentor-protégé program, such as small disadvantaged businesses; women-
owned, veteran-owned and service-disabled veteran-owned businesses; 
HUBZone businesses; and historically black colleges and universities 
and other minority institutions. 

[8] As a result, our objective was to determine if information is 
available on whether protégés have become able to compete for federal 
contracts without the assistance of a mentor. 

[9] According to SBA officials, as a result of protégé firms 
participating in its 8(a) program, the agency collects information on 
the firm for a period of 3 years following completion of either the 9- 
year 8(a) program term or early graduation from the program. However, 
the information is collected for purposes of the 8(a) program and is 
not suitably detailed to determine whether protégés have become able 
to compete for federal contracts. 

[10] DOD's requirement for collecting and maintaining information on 
the protégé after conclusion of the mentor-protégé program derives 
from amendments to the program in the National Defense Authorization 
Act for Fiscal Year 2000, Pub. L. No. 106-65, § 811, 113 Stat. 706 
(1999). 

[11] DOD is also required to verify that mentors and protégés 
accurately reported progress and to determine that all costs 
reimbursed to mentors during the agreement were reasonably incurred. 

[12] DOD Office of Small Business Programs, DOD Mentor-Protégé Program 
Annual Report to Congress, Fiscal Year 2009, (Washington, D.C., August 
2010). 

[13] DOD Office of Small Business Programs, DOD Mentor-Protégé Program 
Annual Report to Congress, Fiscal Year 2007 and Fiscal Year 2008, 
(Washington, D.C., September 2009). 

[14] Most agency officials told us they only collect information on 
protégés during the period in which they are participating in the 
agency's mentor-protégé program, including data on the increase in 
number and dollar value of contacts and subcontracts awarded to the 
protégé. Some agencies also collect information on increases in 
protégé subcontracting opportunities in areas where the protégé had 
not traditionally performed--opportunities that would indicate an 
expansion of its field of expertise. For some agencies, the 
information gathered on the protégé's progress while it is 
participating in the program is used as a measure of overall success 
for their mentor-protégé programs. 

[15] The National Defense Authorization Act for Fiscal Year 2005 
extended the program until September 30, 2010 for approval of new 
agreements, and until September 30, 2013, for only reimbursement of 
incurred costs or credit toward attainment of a subcontracting goal. 

[16] The 8(a) program is one of the federal government's primary 
vehicles for developing small businesses that are owned and controlled 
by socially and economically disadvantaged individuals. Firms in SBA's 
8(a) program receive SBA technical assistance and management training, 
and may be eligible for contracts that federal agencies set aside for 
8(a) firms. SBA's mentor-protégé program serves as an additional 
developmental tool for 8(a) participants and protégés must be 
participants in SBA's 8(a) program. 

[17] Unlike other mentor-protégé programs, SBA's Mentor-Protégé 
Program is administered by the Office of Business Development through 
SBAs district offices and does not involve the OSDBU. 

[18] Effective October 2003, the program transitioned from the Office 
of the Secretary of Defense, OSDBU level to the military services and 
defense agencies. The following military services and defense agencies 
are currently involved: Army, Navy, Air Force, US Special Operations 
Command, Joint Ground Robotics Enterprise, National Geospatial 
Intelligence Agency, National Security Agency, Missile Defense Agency, 
Defense Contract Management Agency, and Defense Logistics Agency (no 
current mentor-protégé agreements). Although it had prior involvement, 
the Defense Information Systems Agency is not currently involved in 
the program. 

[19] The Fiscal Year 1996 Department of Transportation Appropriations 
management system outside of FAR. It developed the FAA Acquisition 
System Toolset, including the Acquisition Management System that 
consists of acquisition policy and guidance specific to FAA. 

[20] DOD and DOE also allow cost reimbursements for mentors under 
their mentor-protégé programs. 

[21] As previously mentioned, SBA's Mentor-Protégé Program is offered 
under its 8(a) Business Development Program. 

[22] According to SBA officials, as a result of protégé firms being 
participants in SBA's 8(a) program, the agency collects information on 
the firm for a period of 3 years following completion of the 9-year 
program term or early graduation from the 8(a) program. However, the 
information is not suitably detailed to determine whether protégés 
have become able to compete for federal contracts. 

[23] National Defense Authorization Act for Fiscal Year 2000, Pub. L. 
No. 106-65, § 811 (1999). 

[24] DOD Mentor-Protege Program Annual Report to Congress, Fiscal Year 
2009, Office of Small Business Programs, August 2010. 

[End of section] 

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