    Small Business: HUBZone Program Suffers From Reporting and
    Implementation Difficulties (26-OCT-01, GAO-02-57).

    Congress created the Historically Underutilized Business Zone
    (HUBZone) program to stimulate economic development and create
    jobs in distressed urban and rural areas, called HUBZones. To
    achieve these goals, the HUBZone program provides more access to
    federal contracting opportunities for small businesses. Reported
    HUBZone program achievements for fiscal year 2000 were
    significantly inaccurate. The inaccuracies resulted from data
    entry errors and insufficient guidance on how to report agency
    data. The federal agencies are having difficulty implementing the
    HUBZone program. The primary reasons that federal contracting
    personnel gave for not using the HUBZone program to award
    contracts were: (1) the small number of Small Business
    Administration (SBA) certified HUBZone firms, (2) difficulty
    identifying certified firms with the capabilities needed by
    federal agencies, (3) SBA's guidance that emphasizes the 8(a)
    program over the HUBZone program, and (4) easier and quicker
    procedures to award contracts under the 8(a) program.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-02-57
        ACCNO:   A02367
      TITLE:     Small Business: HUBZone Program Suffers From Reporting
    and Implementation Difficulties
         DATE:   10/26/2001
      SUBJECT:   Data integrity
    	     Economic development
    	     Program evaluation
    	     Reporting requirements
    	     Small business contracts
    	     SBA 8(a) Program
    	     SBA HUBZone Empowerment Contracting
    	     Program
    	     SBA Pro-Net

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    GAO-02-57

    Report to the Ranking Minority Member, Committee on Small Business and
    Entrepreneurship, U. S. Senate

    United States General Accounting Office

    GAO

    October 2001 SMALL BUSINESS HUBZone Program Suffers From Reporting and
    Implementation Difficulties

    GAO- 02- 57

    Page 1 GAO- 02- 57 Small Business

    October 26, 2001 The Honorable Christopher S. Bond Ranking Minority Member
    Committee on Small Business and Entrepreneurship United States Senate

    Dear Senator Bond: The Congress created the Historically Underutilized
    Business Zone (HUBZone) program to stimulate economic development and create
    jobs in distressed urban and rural areas, called HUBZones. To achieve these
    goals, the HUBZone program provides more access to federal contracting
    opportunities for small businesses. The Small Business Administration (SBA)
    administers the program, and federal agencies report their program
    achievements- the number and value of contract awards- to the Federal
    Procurement Data Center (FPDC). In fiscal year 2000, federal agencies
    reported awarding $663 million in contracts under the HUBZone program. In
    response to your request, we examined (1) whether HUBZone program
    achievements are being accurately reported, and if not, the reasons for
    inaccuracies and (2) whether federal agencies are having difficulty
    implementing the HUBZone program to award contracts to certified HUBZone
    firms, and if so, the reasons for the difficulty.

    Reported HUBZone program achievements for fiscal year 2000 were
    significantly inaccurate. We found that the value of contracts awarded to
    HUBZone firms could be hundreds of millions of dollars different than the
    reported achievements. The federal agencies? data (1) included contracts
    awarded to firms that SBA had not certified as qualified to participate in
    the program, (2) included contracts awarded before the HUBZone program began
    in March 1999, and (3) did not include contracts awarded to firms that SBA
    may have certified as qualified HUBZone firms. We could not conclusively
    determine actual HUBZone program achievements because of these inaccuracies.
    The inaccuracies resulted from data entry errors and insufficient guidance
    on how to report agency data. FPDC includes the inaccurate data in its
    annual report on federal procurement activities. As a result of data
    problems, the Congress and federal agencies cannot use this data to gauge
    the program?s success or to ensure that the program is working as intended.

    United States General Accounting Office Washington, DC 20548

    Results in Brief

    Page 2 GAO- 02- 57 Small Business

    After interviewing contracting officials and analyzing FPDC and SBA
    information, we concluded that federal agencies are having difficulties
    implementing the HUBZone program. Federal agencies did not achieve the
    fiscal year 2000 participation goal of 1.5 percent of the value of all prime
    contract awards. Further, federal agencies obligated only $24 million to
    HUBZone firms as a result of applying the provisions of the HUBZone Act. 1
    The primary reasons that federal contracting personnel gave for not using
    the HUBZone program to award contracts were: (1) the small number of SBA
    certified HUBZone firms, (2) difficulty identifying certified firms with the
    capabilities needed by federal agencies, (3) SBA?s guidance that emphasizes
    the 8( a) program 2 over the HUBZone program, and (4) easier and quicker
    procedures to award contracts under the 8( a) program.

    We are making recommendations to the Office of Federal Procurement Policy
    and SBA concerning the need to more accurately report the achievements under
    the HUBZone program and for additional and clarified guidance on how to more
    effectively locate certified HUBZone firms with capabilities that meet
    agencies? needs. In commenting on a draft of this report, SBA and the Office
    of Federal Procurement Policy generally agreed with our findings and
    provided clarifying suggestions for two recommendations, which we
    incorporated. SBA did express a concern about our characterization of SBA?s
    emphasis on the 8( a) program. We believe our report accurately reflects the
    policies in effect at the time of our review and acknowledges the changes
    initiated by SBA. SBA?s written comments appear in appendix II.

    The Historically Underutilized Business Zone (HUBZone) Act of 1997
    established a program to provide assistance in securing federal contracts to
    small businesses located in HUBZones. HUBZones are metropolitan area census
    tracts or nonmetropolitan counties in which low- income levels or high
    unemployment rates qualify them as economically distressed. Also, all
    federally- recognized Indian reservations are HUBZones. The purpose of the
    HUBZone program is to increase employment opportunities, investment, and
    economic development in these areas.

    1 Title VI of the Small Business Reauthorization Act of 1997 (P. L. 105-
    135). 2 The 8( a) program, also administered by the SBA, is one of the
    federal government?s vehicles for developing small businesses that are owned
    by socially and economically disadvantaged individuals. Background

    Page 3 GAO- 02- 57 Small Business

    The HUBZone Act established (1) eligibility requirements that firms must
    meet to participate in the program, (2) contracting preferences that federal
    agencies can use to award contracts to firms certified by SBA as qualified
    HUBZone firms, and (3) goals for program participation by HUBZone firms as a
    percent of the total value of prime contract awards. The act identified ten
    federal agencies for initial participation in the program through the end of
    fiscal year 2000, and three more agencies were added in November 1999. (See
    appendix I for a list of the 13 agencies.) Currently, the HUBZone program
    applies to all federal agencies. 3

    SBA must certify that a firm qualifies for participation before federal
    agencies can award a contract under the program. To be qualified, the firm
    must apply with SBA and meet the following requirements:

     The firm must be a small business owned and controlled by one or more U.
    S. citizens. 4  The firm?s principal office must be located in a HUBZone.
    Finally, at least 35 percent of the firm?s employees must reside in a

    HUBZone. Once SBA has certified that a firm is qualified, SBA adds the
    firm?s name, address and certification date to its List of Qualified HUBZone
    Small Business Concerns maintained on SBA?s World Wide Web site. In
    addition, SBA adds this certification to the firm?s profile in SBA?s on-
    line PRO- Net database, which contains information supplied by over 200, 000
    small businesses. SBA?s list and PRO- Net are federal contracting officers?
    primary information sources for determining a firm?s eligibility under the
    HUBZone program.

    To increase employment and encourage economic development in areas
    designated as HUBZones, federal agencies can use any of three preferences
    specified in the HUBZone Act when awarding contracts to certified small
    businesses, as follows:

    3 13 CFR part 126.101. 4 The HUBZones in Native America Act of 2000 (P. L.
    106- 554, Title VI), among other things, expanded the definition of HUBZone
    small business ownership and control to include Alaska Native Corporations,
    Indian tribal governments, and community development corporations, and more
    precisely defined the term ?Indian reservation?.

    Page 4 GAO- 02- 57 Small Business

     First, a contracting officer can give a HUBZone firm a price evaluation
    preference when participating in a full and open competition. In these
    cases, the contracting officer can deem the price offered by the HUBZone
    firm as lower than a price offered by another firm if (1) the other firm is
    not a small business and (2) the HUBZone firm?s offered price is not more
    than 10 percent higher than the otherwise lowest price.  Second, a
    contracting officer can set aside a contract for competition only

    among certified HUBZone firms if two or more responsible HUBZone firms are
    expected to submit offers and the agency can award the contract at a fair
    market price. 5  Finally, a contracting officer can award a sole source
    contract to a

    HUBZone firm if the officer determines among other things that two or more
    responsible HUBZone firms are not likely to submit offers and the agency can
    award the contract at a fair and reasonable price.

    The HUBZone Act established participation goals for certified firms starting
    with fiscal year 1999. The fiscal year 1999 goal was 1 percent of the year?s
    total value of prime contract awards, and the fiscal year 2000 goal was 1.5
    percent. The act increased the goal by one- half percent each year, reaching
    3 percent in fiscal year 2003 and each fiscal year thereafter. Because of
    delays in HUBZone program implementation, fiscal year 2000 was the first
    year agencies reported data to FPDC. Under the Small Business Act, SBA must
    report to the Congress and the President on the agencies? achievements in
    meeting their small business goals, including those for HUBZone concerns. 6
    This annual report relies on FPDC data.

    The data that federal agencies reported on fiscal year 2000 HUBZone
    contracting achievements is significantly inaccurate. In fact, we identified
    data inaccuracies that put hundreds of millions of dollars in reported
    achievements in question. The inaccuracies were due to data entry errors and
    insufficient guidance for federal contracting personnel on how to complete
    the forms used to submit data to FPDC. Inaccurate reporting of

    5 A prospective contractor is considered responsible if it has the
    capability and financial resources to perform a contract. FAR 9.104- 1. 6
    The Small Business Act, states that SBA shall annually report to the
    President and the Congress on the extent of participation of small business
    concerns, including qualified HUBZone small business concerns, in agencies?
    procurement contracts. The annual report is called The State of Small
    Business. P. L. 100- 656, as codified in 15U. S. C. 644( h). Reported
    HUBZone

    Program Contracting Achievements Are Inaccurate

    Page 5 GAO- 02- 57 Small Business

    HUBZone achievements limits the ability of federal agencies and the Congress
    to gauge the success of the program.

    For fiscal year 2000, federal agencies reported to FPDC that they awarded
    1,803 contracts valued at $663 million to certified HUBZone firms. However,
    we found that federal agencies were overcounting some achievements while
    potentially undercounting others. First, 61 percent of the reported
    contracts and 53 percent of the reported dollars should not have been
    reported as fiscal year 2000 HUBZone program achievements. Specifically, we
    found that federal agencies actually awarded 1,034 of the 1,803 reported
    HUBZone contracts (with obligations of about $325 million) to firms not
    certified to participate in the HUBZone program. Also, we identified another
    57 contracts with obligations of about $24 million that were awarded before
    the start of the program. Second, when we compared SBA?s contractor
    certification data with FPDC?s contracting activity data, we found that
    federal agencies did not report up to 1,712 contracts- $589 million- awarded
    to firms that may have been qualified as HUBZone program participants.
    However, because FPDC collects only the month and year of contract awards,
    we could not readily compare a firm?s certification date with a specific
    contract award date. As a result, we could not determine the actual number
    or value of contracts awarded to HUBZone firms.

    We identified problems at the contracting officer level and the agencywide
    level that contributed to inaccurate data reported to FPDC. FPDC perpetuates
    these errors by including the inaccuracies in its annual report on federal
    procurement activities.

     First, contracting officers are not accurately filling out the forms used
    to report contracting data to FPDC. In some cases, contracting officers
    simply entered the wrong data when completing the forms. In other cases,
    contracting officers stated that they were unfamiliar with agency forms and
    lacked guidance on how to fill them out. Agency forms change regularly to
    incorporate new reporting requirements or when an agency implements an
    automated reporting system. Contracting officers receive limited guidance on
    completing agency forms from an FPDC manual. An FPDC official agreed that
    the manual does not provide sufficient guidance to preclude errors in
    overcounting or undercounting achievements. FPDC plans to publish additional
    guidance to address these inaccuracies before fiscal year 2002.  Second,
    agencies are unsure of what qualifies as a HUBZone contract

    award because SBA did not provide guidance about which contracts to count
    towards HUBZone program achievements. According to SBA

    Page 6 GAO- 02- 57 Small Business

    officials, a contract awarded to a firm that is not certified to participate
    in the HUBZone program should not count as a HUBZone achievement, regardless
    of whether the firm became certified during the term of the contract.
    However, some agencies are counting obligations on multiple year contracts 7
    even though the contract award occurred before the contractors became
    HUBZone certified. In recent discussions with federal agency officials, SBA
    officials recognized that for some long- term, multiple year contracts,
    following SBA?s current policy could result in agencies not receiving credit
    for directing funds to certified HUBZone firms. Consequently, SBA is
    reviewing its policy on which contract obligations to count towards the
    HUBZone program.  Third, FPDC perpetuates inaccurate reporting by
    publishing reports that

    contain known errors. FPDC checks agency- provided data to identify apparent
    inconsistencies, notifies agencies of the errors identified, and requests
    corrective actions. Agencies took varying degrees of corrective action on
    errors identified in the preliminary HUBZone data for fiscal year 2000, but
    they did not correct all the errors that FPDC identified. An FPDC official
    stated that FPDC does not have the knowledge to correct the data nor the
    authority to require agencies to correct the data. As a result, the data
    appears as reported by federal agencies.

    SBA relies on FPDC data to report on the HUBZone program to the President
    and the Congress. SBA?s Associate Administrator for the HUBZone program
    stated that HUBZone information in SBA?s fiscal year 2000 report on small
    business programs will have to include a disclaimer because of data
    inaccuracies.

    Despite the inaccuracies in FPDC data, we determined that there are problems
    implementing the HUBZone program. None of the original ten agencies
    authorized to implement the program met the fiscal year 2000 statutory goal
    of awarding 1.5 percent of their prime contract awards to HUBZone firms.
    Further, one agency awarded only one contract to a HUBZone firm, and another
    did not award any. Moreover, our analysis of the agencies? contract awards
    revealed that out of the 10 agencies, 7 used

    7 Multiple year contracts contain option years beyond a base period that the
    agencies can exercise so the contractors can continue performing the
    contract. After the contractors begin performance on the multiple year
    contract, the SBA may certify the firm as a HUBZone firm. In such cases,
    when exercising contract options, the agencies are counting the amounts paid
    to the firm subsequent to certification as HUBZone contract awards. Federal
    Agencies Are

    Having Difficulty Implementing the HUBZone Program

    Page 7 GAO- 02- 57 Small Business

    the HUBZone Act preferences to award only 52 contracts with $24 million in
    obligations.

    Contracting officers and agency officials confirmed that they are having
    difficulty implementing the program and cited several reasons for this.
    First, there is a relatively small number of certified HUBZone firms. We
    found that in approximately 8,000 HUBZones, SBA had certified 290 firms for
    participation in the program at the start of fiscal year 2000 and by the end
    of the fiscal year had certified a total of 1,940 firms nationwide.
    According to several contracting officers and SBA officials, many small
    businesses are not aware of the need to apply for certification. To address
    this problem, SBA officials and agency contracting officers have been
    informing small businesses about HUBZone program requirements, helping them
    complete applications to get certified, and holding seminars to encourage
    more applications. However, while the number of applications to SBA has
    increased significantly in 2001, the number of certifications has not. As of
    September 30, 2001, SBA had certified about 4,100 firms.

    Second, contracting officers cannot easily locate certified HUBZone firms
    that provide particular goods and services. Contracting officers told us
    that they rely on SBA?s PRO- Net database as a primary source for
    identifying potential HUBZone firms. However, sometimes the information the
    companies enter into the database is not specific or reliable enough to
    ascertain the firms? capabilities. For example, a General Services
    Administration contracting officer stated that building mechanical
    maintenance is a common capability cited by firms listed in PRO- Net, but he
    had difficulty identifying a company that could perform mechanical
    maintenance on building elevators. SBA officials stated that they
    periodically remind the small businesses of the need to regularly update
    their PRO- Net information so that the database contains the information
    needed by federal contracting personnel.

    Third, SBA instructs agencies in informal guidance to place more emphasis on
    the 8( a) program than the HUBZone program when federal agencies award
    contracts to small businesses. Specifically, the SBA guidance ranks the
    small business programs and places an 8( a) firm that is also a certified
    HUBZone firm before an 8( a) firm and an 8( a) firm before a

    Page 8 GAO- 02- 57 Small Business

    HUBZone firm. 8 Because several agencies expressed concerns about the
    perceived lack of flexibility in this order of precedence, SBA is reviewing
    its guidance in this regard.

    Finally, it is easier and quicker for agency officials to award a contract
    using the 8( a) sole source program. A contracting officer can notify the
    SBA of the intent to award a sole source contract to an 8( a) firm by
    providing a brief justification for the selection of the specific 8( a) firm
    and can negotiate directly with the firm to achieve a fair market contract
    price. Federal agencies can complete this process in as few as 3 months. In
    contrast, a contracting officer must determine that only one HUBZone firm
    exists to perform the work on a sole source contract to a HUBZone firm.
    Contracting officials can determine this (1) by conducting market research
    or (2) by having only one responsible firm respond to an announcement for a
    HUBZone set- aside procurement. A contracting officer stated that completing
    this process could take as long as a year.

    Accurate reporting of HUBZone program information would allow federal
    officials to better gauge the success of the program. However, the quality
    of fiscal year 2000 HUBZone contracting data that federal agencies reported
    to the FPDC was not credible. Without accurate data, the Congress and the
    President are not able to ensure that the program is working as intended to
    provide assistance to economically distressed areas of the United States.
    Most of the reporting errors could have been avoided had contracting
    personnel had adequate guidance on how to complete the forms submitted to
    FPDC. Also, some errors could be corrected if the federal agencies and FDPC
    work together to address the inaccuracies identified in FPDC?s review of
    data.

    Further, the ten federal agencies that Congress charged with implementing
    the program awarded only 52 contracts using HUBZone Act preferences during
    all of fiscal year 2000. Clearer guidance on how firms should inform
    agencies about their capabilities would enable contracting officers to more
    easily locate firms for specific contract opportunities and could increase
    the number of contracts awarded to certified HUBZone firms using the act?s
    preferences.

    8 While SBA?s regulations (13 CFR 126.607) and the Federal Acquisition
    Regulation (FAR 19.800( e)) allow contracting officers discretion when
    deciding whether to use the 8( a) or HUBZone programs, federal agencies
    usually rely on SBA?s informal guidance on the order of precedence when
    awarding contracts to small businesses. Conclusions

    Page 9 GAO- 02- 57 Small Business

    To improve the accuracy of the data reported by federal agencies, we
    recommend the Administrator, Office of Federal Procurement Policy, in
    consultation with SBA when appropriate, strengthen the guidance for all
    federal agencies about reporting small business program contracting
    activities to the Federal Procurement Data Center. At a minimum, this
    guidance should address how the forms should be completed and verified, and
    clarify how to report which small business preference program was used to
    award the contract.

    To improve the accuracy of data at an agencywide level, we recommend the
    Administrator of SBA develop guidance for all federal agencies about
    identifying contracts to be reported to the FPDC that meet the HUBZone Act
    criteria.

    To help ensure that FPDC does not perpetuate data inaccuracies, we also
    recommend that the Administrator, Office of Federal Procurement Policy,
    develop follow- up review procedures to emphasize to federal agencies their
    responsibility in providing accurate data and promptly correcting inaccurate
    data.

    To help contracting officers identify firms with the appropriate
    capabilities, we also recommend the Administrator of SBA inform small
    businesses listed in PRO- Net about the importance of entering and
    maintaining timely, complete, and accurate data.

    We received written comments from SBA and oral comments from the Office of
    Federal Procurement Policy on a draft of this report. SBA generally agreed
    with our findings and recommendations although SBA had three concerns.
    First, SBA suggested that the first recommendation be revised to indicate
    that the Office of Federal Procurement Policy should consult with SBA in
    developing new guidance. We revised the recommendation accordingly. Second,
    SBA felt that our report title could be misleading and suggested that our
    title should be changed to HUBZone Program Suffers From Procuring Agency
    Reporting and Implementation Difficulties. We believe our title
    appropriately captures the findings of our review, with which SBA agreed;
    therefore, we did not make this change. Third, SBA took issue with our
    characterization of the emphasis given to the 8( a) program relative to the
    HUBZone program. SBA cited a letter the agency sent to Senator Bond dated
    August 17, 2001, which states that there is parity between the 8( a) program
    and the HUBZone program, although ?regulatory language could be read to give
    priority to awards to the 8( a) program over HUBZone awards.? We noted in
    our report that Recommendations for

    Executive Action Agency Comments and Our Evaluation

    Page 10 GAO- 02- 57 Small Business

    regulations allow contracting officer?s discretion in deciding on whether to
    use the 8( a) or HUBZone programs when awarding contracts. However, SBA?s
    training materials on the HUBZone program, which are given to federal
    agencies, establish an order of precedence giving the 8( a) program priority
    over the HUBZone program. As noted in our report and SBA?s August 17th
    letter, SBA is drafting changes to its HUBZone and 8( a) regulations to
    clarify that contracting officers have discretion to use either program.
    Therefore, we believe our report accurately reflects SBA?s guidance at the
    time of our review. SBA?s comments and enclosure appear in appendix II.

    The Office of Federal Procurement Policy generally agreed with our findings.
    However, based on the Office of Federal Procurement Policy?s comments, we
    revised the recommendation on FPDC reported data to clarify the role that
    the Office of Federal Procurement Policy should play in ensuring the
    accuracy of data that agencies provide to FPDC.

    To determine whether federal agencies are accurately reporting HUBZone
    contract achievements, we obtained FPDC?s database of all reported
    obligations to federal government contracts during fiscal year 2000 and
    SBA?s official list of certified HUBZone firms. We reviewed the database and
    list for three kinds of potential inaccuracies in the FPDC database: (1)
    contracts reported as HUBZone contracts that were awarded to firms not
    certified as HUBZone firms, (2) contracts reported as HUBZone contracts that
    were awarded to firms certified after contract award, and (3) contracts not
    reported as HUBZone contracts that were awarded to firms that were certified
    HUBZone firms.

    To determine whether federal agencies are having difficulty implementing the
    HUBZone program to award contracts to certified HUBZone firms, and if so,
    the reasons for the difficulty, we reviewed the HUBZone Act of 1997 and
    other pertinent legislation; and HUBZone program implementation guidance
    contained in Title 13, Code of Federal Regulations (CFR), Part 126 (13 CFR
    126), contracting guidance contained in the Federal Acquisition Regulation
    (48 CFR Chapter 1), and other relevant guidance issued by SBA, FPDC, and the
    ten program implementing agencies (listed in appendix I). We held
    discussions about HUBZone program management with officials at the Small
    Business Administration. We also held discussions with procurement officials
    at the Small and Disadvantaged Business Utilization Office, and HUBZone
    program officials at the headquarters level of the ten agencies identified
    in the HUBZone Act and various field locations of six of those agencies.
    Scope and

    Methodology

    Page 11 GAO- 02- 57 Small Business

    In addition, we determined the extent that agencies used the HUBZone
    preferences to award contracts. We used FPDC data to identify 136 contracts
    that the 10 federal agencies reported as being awarded using preferences in
    fiscal year 2000. We requested relevant contract file information for each
    of the contracts. We also discussed contract file information with selected
    contracting officers, who were responsible for 39 of these contracts.

    We conducted our review between December 2000 and October 2001 in accordance
    with generally accepted government auditing standards.

    As requested by your office, unless you publicly announce the contents of
    this report earlier, we plan no further distribution of it until 30 days
    from the date of this letter. At that time, we will send copies to other
    interested congressional committees and the secretaries of Defense,
    Agriculture, Health and Human Services, Transportation, Energy, Housing and
    Urban Development, and Veterans Affairs. We will send copies to the
    Director, Office of Management and Budget; the Administrator, General
    Services Administration; the Administrator, SBA; the Administrator, NASA;
    the Administrator, EPA; and the Administrator, Office of Federal Procurement
    Policy. We will also make copies available to others upon request.

    Please contact me at (202) 512- 4125 or Hilary Sullivan at (214) 777- 5652
    if you have any questions regarding this report. Major contributors to this
    report were Frederick G. Day, John E. Clary, and Enemencio S. Sanchez.

    Sincerely yours, David E. Cooper Director Acquisition and Sourcing
    Management

    Appendix I: Federal Agencies Initially Designated to Implement the HUBZone
    Program

    Page 12 GAO- 02- 57 Small Business

    Agencies designated in the HUBZone Act of 1997 (P. L. 105- 135), December 2,
    1997:

    1. Department of Defense 2. Department of Agriculture 3. Department of
    Health and Human Services 4. Department of Transportation 5. Department of
    Energy 6. Department of Housing and Urban Development 7. Department of
    Veterans Affairs 8. Environmental Protection Agency 9. National Aeronautics
    and Space Administration 10. General Services Administration (Each of these
    ten agencies was included in our review.) Agencies Added by the Fiscal Year
    2000 Appropriation Act (P. L. 106- 113), November 29, 1999:

    11. Department of Commerce 12. Department of Justice 13. Department of State
    (None of these three agencies was included in our review.) Appendix I:
    Federal Agencies Initially

    Designated to Implement the HUBZone Program

    Appendix II: Comments From the Small Business Administration

    Page 13 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Appendix II: Comments From the Small Business Administration

    Page 14 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 15 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 16 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 17 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 18 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 19 GAO- 02- 57 Small Business

    Appendix II: Comments From the Small Business Administration

    Page 20 GAO- 02- 57 Small Business (120012)

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    Contact one:

     Web site: http:// www. gao. gov/ fraudnet/ fraudnet. htm  E- mail:
    fraudnet@ gao. gov  1- 800- 424- 5454 (automated answering system) Ordering
    Information

    To Report Fraud, Waste, and Abuse in Federal Programs
    *** End of document. ***