This post is the third and final in a series I have written about the SBA's WOSB program in an attempt to better understand and answer my questions surrounding it.
Government programs, by nature, are difficult to implement. It is even more difficult to understand the effectiveness of large programs once implemented. These programs take time to influence the federal purchasing geography, making course correction a constant work in progress. We should explore issues and concerns with the program. Specifically, is the program working as intended? Why has the program been investigated by the Government Accountability Office (GAO) and the Office of Inspector General (OIG)?
The GAO was tasked with studying the WOSB Program in 2014. The GAO identified several concerns with the WOSB program. Third-Party certification is essentially assessing a fee for the free program (note, legislation has been passed to amend and remove the self-certification rule). The program requires the same documentation to be uploaded, regardless of self-certification or third-party certification. The SBA does not track whether a business is self- or third-party certified. The contracting officers, not the SBA, are responsible for reviewing the documents submitted to ensure they are all present but does not charge them with ensuring the documents are all valid, as logic would imply. Contracting officers are only granted access to the WOSB program repository after they have selected an awardee. SBA does not have a process for auditing third-party certifiers to ensure they are qualifying eligible businesses and to ensure that they make the applicants aware of the no cost option to self-certify. High ineligibility rates have been found in studies conducted on program eligibility. SBA is developing monthly third-party supplier report reviews but has not given a date for the standard operating procedure release.
The OIG was charged with investigating the WOSB Program to determine if the set-aside requirements were being complied with and if the benefit-receiving firms met the self-certification requirements. The OIG found that the Federal contracting officers were not properly informed of their responsibilities to vet the contract applicants to ensure they met requirements. The OIG also found that some of the contract applicants did not meet the documentation requirements. Documentation was either incorrect or, in some cases, not available. The solution? Increased training for federal contracting officers and WOSB Program participants. The OIG also recommended some slight program changes like revising the self-certification rule, revising the financial information form, and performing eligibility exams.
Internal governmental investigations aside, the question remains: Is the WOSB Program working as intended? I would venture to say “yes.” From my research and the 5% federal budget allocation to women-owned businesses announced earlier this year, I believe the program is working as intended. Could it use some process updates? Yes. Could the program steps be simplified? Yes. Over the course of this year, the SBA has released some helpful materials that break the program down into simpler terms. Program improvements are on their way!
Over the course of this blog series, we have uncovered the purpose and history of the WOSB program at the Small Business Administration. Please check out the previous two posts here and here. I have enjoyed researching the program and relaying that research to you. This will be my final post in my WOSB series. Thanks for reading!