Recommendation: The SBA Administrator or her designee should (1) develop a process for periodically reviewing Federal Procurement Data System-Next Generation (FPDS-NG) data to determine the extent to which agencies are awarding WOSB program set-asides under ineligible North American Industry Classification System (NAICS) codes and (2) take steps to address any issues identified, such as providing targeted outreach or training to agencies making awards under ineligible codes. (Recommendation 1)

Agency: Small Business Administration
Status: Open

Comments: In May 2019, SBA analyzed FPDS-NG data to review the use of ineligible NAICS codes in the WOSB program. SBA officials also noted that they plan to conduct these reviews on an ongoing basis. As part of their May 2019 analysis, SBA identified federal agencies that had used ineligible NAICS codes. As of October 2019, SBA officials said that they were taking steps, including drafting presentation materials, to provide training on NAICS codes to agencies and planned to present quarterly at the Small Business Procurement Advisory Council FY 2020 meetings. SBA officials also noted that they had also provided training on NAICS codes as part of its FY 2019 performance reviews of procurement centers.

Recommendation: The Secretary of Veterans Affairs should ensure that VA's Director of the Office of Acquisition and Logistics, in consultation with VA's Office of Small and Disadvantaged Business Utilization, takes measures to ensure that VA contracting staff adhere to the requirements for documenting the required Vendor Information Pages searches in contract files. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA reported that it was beginning a process to update its contracting system to automate the inclusion of documentation of Vendor Information Pages searches in contract files. VA is also now tracking compliance rates. VA plans to provide GAO an update in fall 2020.

Recommendation: The Secretary of Veterans Affairs should ensure that the Director of the Office of Acquisition and Logistics conducts a fraud risk assessment for the Veterans First program. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA provided GAO with a draft fraud risk assessment, and also reported that it is developing measures to mitigate identified risks. VA has not yet provided a date by which it plans to finalize its risk assessment and risk mitigation measures.

Recommendation: The Secretary of Veterans Affairs should ensure that the Director of the Office of Acquisition and Logistics directs the Risk Management and Compliance Service to share, through guidance, training, or other methods, subcontracting limitation risks and monitoring practices with contracting officers and their management. (Recommendation 6)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA provided draft lists of subcontracting limitations risks, as well as draft monitoring guidance and tools. After these items are finalized, VA plans to post them on a portal accessible to all VA contracting staff, but has yet to provide a date by which it expects to take this step.

Recommendation: To provide reasonable assurance that DOD's Pilot Mentor-Protege Program meets its mission, the Director, DOD's Office of Small Business Programs, should conduct periodic reviews of the processes DOD components follow to approve agreements and take oversight actions, as appropriate.

Agency: Department of Defense: Office of Small Business Programs
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation and stated that it would implement a new standard operating procedure for DOD's Mentor-Protege Program component program managers. According to DOD, the new standard operating procedure would require each component program manager to provide quarterly program management review reports to DOD's Office of Small Business Programs, in addition to annual and monthly reporting, as required by Appendix I of DOD's policies and procedures for the Mentor-Protege Program. DOD's new Standard Operating Procedure would also centralize the implementation of the Mentor Protege Program and, according to DOD, would create process efficiency, and enhanced oversight of the program. The new Standard Operating Procedure would also include a new standardized checklist each Mentor-Protege Program component would utilize to approve mentor protege agreements. The standardized checklist would also include the company North American Industry Classification System code, a mentor approval letter, and a fully completed copy of the mentor protege agreement signed by both parties. Last, DOD would then determine program improvement, once the aforementioned controls are implemented and monitored for effectiveness. As of August 2018, DOD had not provided GAO with documentation of the new standard operating procedure. GAO will continue to monitor the department's progress in implementing this recommendation.

Recommendation: To provide reasonable assurance that DOD's Pilot Mentor-Protege Program meets its mission, the Director, DOD's Office of Small Business Programs, should complete actions to develop performance goals and related measures that are consistent with the program's stated purpose.

Agency: Department of Defense: Office of Small Business Programs
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation and stated that Mentor-Protege Program components would establish goals for the Mentor Protege Program and those goals would be focused on the Industrial Base and Technology Transfer categories. In addition, DOD stated that it would establish additional surveillance requirements to ensure prime and subcontract opportunities are afforded to the proteges and that instituting a baseline performance goal for all components will ensure the Program achieves the intent desired by Congress. As of August 2018, DOD had not provided GAO with documentation of the new goals or standard operating procedure. GAO will continue to monitor the department's progress in implementing this recommendation.