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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