HUBZone Program
Fraud and Abuse Identified in Four Metropolitan Areas Gao ID: GAO-09-519T March 25, 2009Created in 1997, the HUBZone program provides federal contracting assistance to small businesses in economically distressed communities, or HUBZone areas, with the intent of stimulating economic development in those areas. On July 17, 2008, we testified before Congress that SBA's lack of controls over the HUBZone program exposed the government to fraud and abuse and that SBA's mechanisms to certify and monitor HUBZone firms provide limited assurance that only eligible firms participate in the program. In our testimony, we identified 10 firms from the Washington, D.C., metropolitan area that were participating in the HUBZone program even though they clearly did not meet eligibility requirements. Of the 10 firms, 6 did not meet both principal office and employee residency requirements while 4 met the principal office requirement but significantly failed the employee residency requirement. We reported in our July 2008 testimony that federal agencies had obligated a total of nearly $26 million in HUBZone contract obligations to these 10 firms since 2006. After the hearing, Congress requested that we perform a follow-on investigation. We describe the results of this investigation and further background about the HUBZone program in a companion report that is being made public today. This testimony will summarize our overall findings. Specifically, this testimony will address (1) whether cases of fraud and abuse in the program exist outside of the Washington, D.C., metro area; (2) what actions, if any, SBA has taken to establish an effective fraud prevention system for the HUBZone program; and (3) what actions, if any, SBA has taken on the 10 firms that we found misrepresented their HUBZone status in July 2008.
In summary, we found that fraud and abuse in the HUBZone program extends beyond the Washington, D.C., area. We identified 19 firms in Texas, Alabama, and California participating in the HUBZone program that clearly do not meet program requirements (i.e., principal office location or percentage of employees in HUBZone and subcontracting limitations). In fiscal years 2006 and 2007, federal agencies obligated nearly $30 million to these 19 firms for performance as the prime contractor on HUBZone contracts and a total of $187 million on all federal contracts. Although SBA has initiated steps to strengthen its internal controls as a result of our 2008 testimonies and report, substantial work remains for incorporating a fraud prevention system that includes effective fraud controls consisting of (1) front-end controls at the application stage, (2) fraud detection and monitoring of firms already in the program, and (3) the aggressive pursuit and prosecution of individuals committing fraud. SBA has taken some enforcement steps on the 10 firms previously identified by GAO that knowingly did not meet HUBZone program requirements. However, as of February 2009, according to SBA's Dynamic Small Business Web site, 7 of the 10 firms that we investigated were still HUBZone certified. SBA's failure to promptly remove firms from the HUBZone program and examine some of the most egregious cases from our testimony has resulted in an additional $7.2 million in HUBZone obligations and about $25 million in HUBZone contracts to these firms.
GAO-09-519T, Hubzone Program: Fraud and Abuse Identified in Four Metropolitan Areas
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Testimony:
Before the Committee on Small Business, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 2:00 p.m. EDT:
Wednesday, March 25, 2009:
HUBZone Program:
Fraud and Abuse Identified in Four Metropolitan Areas:
Statement of Gregory D. Kutz, Managing Director:
Forensic Audits and Special Investigations:
GAO-09-519T:
Madam Chairwoman and Members of the Committee:
Thank you for the opportunity to discuss the results of our
investigation of the Small Business Administration's (SBA) Historically
Underutilized Business Zone (HUBZone) program. Created in 1997, the
HUBZone program provides federal contracting assistance to small
businesses in economically distressed communities, or HUBZone areas,
with the intent of stimulating economic development in those areas. On
July 17, 2008, we testified before this committee that SBA's lack of
controls over the HUBZone program exposed the government to fraud and
abuse[Footnote 1] and that SBA's mechanisms to certify and monitor
HUBZone firms provide limited assurance that only eligible firms
participate in the program.[Footnote 2] In our testimony, we identified
10 firms from the Washington, D.C., metropolitan area that were
participating in the HUBZone program even though they clearly did not
meet eligibility requirements. Of the 10 firms, 6 did not meet both
principal office and employee residency requirements while 4 met the
principal office requirement but significantly failed the employee
residency requirement.[Footnote 3] We reported in our July 2008
testimony that federal agencies had obligated a total of nearly $26
million in HUBZone contract obligations to these 10 firms since 2006.
After the hearing, you requested that we perform a follow-on
investigation. We describe the results of this investigation and
further background about the HUBZone program in a companion report that
is being made public today.[Footnote 4] This testimony will summarize
our overall findings. Specifically, this testimony will address (1)
whether cases of fraud and abuse in the program exist outside of the
Washington, D.C., metro area; (2) what actions, if any, SBA has taken
to establish an effective fraud prevention system for the HUBZone
program; and (3) what actions, if any, SBA has taken on the 10 firms
that we found misrepresented their HUBZone status in July 2008.
To meet these objectives, we identified and investigated selected
HUBZone firms based on certain criteria, such as magnitude of HUBZone
contracts and firm location. We also interviewed SBA officials and
reviewed SBA data. A more detailed discussion of our scope and
methodology is provided in our separate report. We conducted our
investigation from September 2008 through March 2009 in accordance with
quality standards for investigations as set forth by the President's
Council on Integrity and Efficiency.
In summary, we found the following:
* Fraud and abuse in the HUBZone program extends beyond the Washington,
D.C., area. We identified 19 firms in Texas, Alabama, and California
participating in the HUBZone program that clearly do not meet program
requirements (i.e., principal office location or percentage of
employees in HUBZone and subcontracting limitations). In fiscal years
2006 and 2007, federal agencies obligated nearly $30 million to these
19 firms for performance as the prime contractor on HUBZone contracts
and a total of $187 million on all federal contracts.
* Although SBA has initiated steps to strengthen its internal controls
as a result of our 2008 testimonies and report, substantial work
remains for incorporating a fraud prevention system that includes
effective fraud controls consisting of (1) front-end controls at the
application stage, (2) fraud detection and monitoring of firms already
in the program, and (3) the aggressive pursuit and prosecution of
individuals committing fraud.
* SBA has taken some enforcement steps on the 10 firms previously
identified by GAO that knowingly did not meet HUBZone program
requirements. However, as of February 2009, according to SBA's Dynamic
Small Business Web site, 7 of the 10 firms that we investigated were
still HUBZone certified. SBA's failure to promptly remove firms from
the HUBZone program and examine some of the most egregious cases from
our testimony has resulted in an additional $7.2 million in HUBZone
obligations and about $25 million in HUBZone contracts to these firms.
Selected Case Studies of Fraud and Abuse Outside the Washington, D.C.,
Metro Area:
HUBZone program fraud and abuse continues to be problematic for the
federal government. We identified 19 firms in Texas, Alabama, and
California participating in the HUBZone program even though they
clearly do not meet program requirements (i.e., principal office
location or percentage of employees residing in the HUBZone and
subcontracting limitations).[Footnote 5] Although we cannot conclude
whether this is a systemic problem based on these cases, the issue of
misrepresentation clearly extends beyond the Washington, D.C.,
metropolitan area where we conducted our initial investigation. In
fiscal years 2006 and 2007, federal agencies had obligated nearly $30
million to these 19 firms for performance as the prime contractor on
federal HUBZone contracts.[Footnote 6]
HUBZone regulations also place restrictions on the amount of work that
can be subcontracted to non-HUBZone firms. Specifically, HUBZone
regulations generally require a firm to expend at least 50 percent of
the personnel costs of a contract on its own employees. As part of our
investigative work, we found examples of service firms that
subcontracted most HUBZone contract work to other non-HUBZone firms and
thus did not meet this program requirement. When a firm subcontracts
the majority of its work to other non-HUBZone firms, it is undermining
the HUBZone program's stated purpose of stimulating development in
economically distressed areas, as well as evading eligibility
requirements for principal office and 35 percent residency requirement.
Examples of firms that did not meet HUBZone requirements included the
following:
* An environmental consulting firm located in Fort Worth, Texas, that
violated HUBZone program requirements because it did not expend at
least 50 percent of personnel costs on its own employees or use
personnel from other HUBZone firms.[Footnote 7] From fiscal year 2006
through fiscal year 2007, the Department of the Army obligated more
than $2.3 million in HUBZone contracts to this firm. At the time of our
investigation, company documents showed that the company was
subcontracting from 71 to 89 percent of its total contract obligations
to other non-HUBZone firms--in some cases, large firms. The principal
admitted that her firm was not meeting the subcontracting performance
requirement of HUBZone regulations. Further, the principal stated that
the firm made bids on HUBZone contracts knowing that the company would
have to subcontract work to other firms after the award. The principal
added that other large firms use HUBZone firms in this manner,
referring to these HUBZone firms as "contract vehicles."
* A ground maintenance services company located in Jacksonville,
Alabama, failed to meet both principal office and 35 percent residency
requirements. From fiscal year 2006 through fiscal year 2007, this firm
received more than $900,000 in HUBZone set-aside obligations. However,
our investigation found that the purported principal office was in fact
a residential trailer occupied by someone not associated with the
company. The company had represented its office as located in "suite
19," when in reality, the address was associated with trailer 19 in a
residential trailer park. The two employees of the firm--a father and a
son--lived in non-HUBZone areas that are located about 90 miles from
the trailer park. This firm also subcontracted most of its HUBZone work
to non-HUBZone firms.
* An information technology firm in Huntsville, Alabama, failed to meet
both principal office and 35 percent residency requirements. From
fiscal year 2006 through fiscal year 2007, federal agencies obligated
over $5 million in HUBZone awards to this firm, consisting mainly of
two HUBZone set-aside contracts. Based on our review of payroll records
and written correspondence that we received from the firm, we
determined that only 18 of 116 of the firm's employees (16 percent) who
were employed in December 2007 lived in HUBZone-designated areas. In
addition, our investigation found that no employees were located at the
location listed as a principal office. The firm's president
acknowledged that he "had recently become aware" that he was not in
compliance with HUBZone requirements and was taking "corrective
actions." However, the firm continued to represent itself as a HUBZone
firm even after this acknowledgment.
According to HUBZone regulations, persons or firms are subject to
criminal penalties for knowingly making false statements or
misrepresentations in connection with the HUBZone program, including
failure to correct "continuing representations" that are no longer
true. During the application process, applicants are not only reminded
of the program eligibility requirements, but are required to agree to
the statement that anyone failing to correct "continuing
representations" shall be subject to fines, imprisonment, and
penalties. Further, the Federal Acquisition Regulation (FAR) requires
all prospective contractors to update the government's Online
Representations and Certifications Application, which includes a
statement certifying whether the firm is currently a HUBZone firm and
that there have been "no material changes in ownership and control,
principal office, or HUBZone employee percentage since it was certified
by the SBA." Of the 19 firms that did not meet HUBZone eligibility
requirements, we found that all of them continued to represent
themselves as eligible HUBZone interests to SBA. Because the 19 case
examples clearly are not eligible, we consider each firm's continued
representation indicative of fraud, abuse, or both related to this
program.
SBA Has Not Incorporated Effective Fraud Controls:
Our June 2008 report[Footnote 8] and July 2008 testimony clearly showed
that SBA did not have effective internal controls related to the
HUBZone program. In response to our findings and recommendations, SBA
initiated a process of reengineering the HUBZone program. SBA officials
stated that this process is intended to make improvements to the
program that are necessary for making the program more effective while
also minimizing fraud and abuse. To that end, SBA has hired business
consultants and reached out to GAO in an attempt to identify control
weaknesses in the HUBZone program and to strengthen its fraud
prevention controls. As of the end of our fieldwork, SBA did not have
in place the key elements of an effective fraud prevention system.
[Footnote 9] A well-designed fraud prevention system (which can also
be used to prevent waste and abuse) should consist of three crucial
elements: (1) up-front preventive controls, (2) detection and monitoring,
and (3) investigations and prosecutions. For the HUBZone program this
would mean (1) front-end controls at the application stage, (2) fraud
detection and monitoring of firms already in the program, and (3)
decertification from the program of ineligible firms and the aggressive
pursuit and prosecution of individuals committing fraud.
Preventive controls. We have previously reported that fraud prevention
is the most efficient and effective means to minimize fraud, waste, and
abuse.[Footnote 10] Thus, controls that prevent fraudulent firms and
individuals from entering the program in the first place are the most
important element in an effective fraud prevention program. SBA
officials stated that as part of their interim process they are now
requesting from all firms that apply to the HUBZone program
documentation that demonstrates their eligibility. While requiring
additional documentation has some value as a deterrent, the most
effective preventive controls involve the verification of information,
such as verifying a principal office location through an unannounced
site visit. Moreover, SBA did not adequately field-test its interim
process for processing applications. If it had done so, SBA would have
known that it did not have the resources to effectively carry out its
review of applications in a timely manner. As a result, SBA had a
backlog of about 800 HUBZone applications as of January 2009. At that
time, SBA officials stated that it would take about 6 months to process
each HUBZone application--well over the 1 month goal set forth in SBA
regulations.
Detection and monitoring. Although preventive controls are the most
effective way to prevent fraud, continual monitoring is an important
component in detecting and deterring fraud. We reported in June 2008
that the mechanisms SBA used to monitor HUBZone firms provided limited
assurance that only eligible firms participate in the program. SBA
officials stated that during this fiscal year, they will be conducting
program examinations on all HUBZone firms that received contracts in
fiscal year 2007 to determine whether they still meet HUBZone
requirements. In addition, SBA officials stated that as of September
2008, SBA had eliminated its backlog of recertifications. Although SBA
has initiated several positive steps, SBA will need to make further
progress to achieve an effective fraud monitoring program, including
steps to (1) verify the validity of a stated principal office during
its recertification and application processes; (2) establish a
streamlined and risk-based methodology for selecting firms for program
examinations going forward; (3) incorporate an "element of surprise"
into its program examinations, such as using random, unannounced site
visits; and (4) review whether HUBZone firms are expending at least 50
percent of the personnel costs of a contract on their own personnel.
Investigation and prosecution. The final element of an effective fraud
prevention system is the aggressive investigation and prosecution of
individuals who commit fraud against the federal government. However,
SBA currently does not have an effective process for investigating
fraud and abuse within the HUBZone program. To date, other than the
firms identified by our prior investigation, the SBA program office has
never referred any firms for debarment and/or suspension proceedings
based on findings from its program eligibility reviews. By failing to
hold firms accountable, SBA has sent a message to the contracting
community that there is no punishment or consequences for committing
fraud or abusing the intent of the HUBZone program.
SBA Has Initiated Some Enforcement Actions against 10 HUBZone Firms
Previously Investigated by GAO:
SBA has taken some enforcement steps on the 10 firms that we found did
not meet HUBZone program requirements as of July 2008. According to
SBA, as of January 2009, 2 of the firms have been removed from the
program and 2 others are in the process of being removed.[Footnote 11]
However, SBA's failure to examine some of the most egregious cases we
previously identified[Footnote 12] has resulted in an additional $7.2
million in HUBZone obligations and about $25 million in HUBZone set-
aside or price preference contracts to these firms.
In the written statement for the July 2008 hearing, the Acting
Administrator of SBA stated that SBA would take "immediate steps to
require site visits for those HUBZone firms that have received HUBZone
contracts and will be instituting suspension and debarment proceedings
against firms that have intentionally misrepresented their HUBZone
status." However, as of February 2009, according to SBA's Dynamic Small
Business Web site, 7 of the 10 firms that we investigated were still
HUBZone certified. SBA has removed 2 firms from the HUBZone program and
is in the process of providing due process to 2 additional firms to
determine whether they should be removed.[Footnote 13] SBA officials
stated that no action will be taken on 3 firms because SBA's program
evaluations concluded that these firms met all the eligibility
requirements of the HUBZone program. We attempted to verify SBA's work,
but were not provided with the requested documentation to support its
conclusion that the firms moved into compliance after our July 2008
testimony. SBA officials said that they have not yet performed program
evaluations for 3 of the most egregious firms because they are
experiencing technical problems with SBA's caseload system. As such,
these 3 firms remain eligible to receive HUBZone set-aside contracts.
SBA is also pursuing suspension and debarment actions for 7 of these
firms, and the Department of Justice is considering civil actions in 5
of the 10 cases.
Recommendations for Executive Action:
We will be referring all the cases we identified to SBA for further
action. In our report, we also recommended that the Administrator of
SBA expeditiously implement our June 2008 recommendations and take the
following four actions:
* Consider incorporating a risk-based mechanism for conducting
unannounced site visits as part of the screening and monitoring
process.
* Consider incorporating policies and procedures into SBA's program
examinations for evaluating if a HUBZone firm is expending at least 50
percent of the personnel costs of a contract using its own employees.
* Ensure appropriate policies and procedures are in place for the
prompt reporting and referral of fraud and abuse to SBA's Office of
Inspector General as well as SBA's Suspension and Debarment Official.
* Take appropriate enforcement actions on the 19 HUBZone firms we found
to violate HUBZone program requirements to include, where applicable,
immediate removal or decertification from the program, and coordination
with SBA's Office of Inspector General as well as SBA's Suspension and
Debarment Official.
In written comments on a draft of our report, SBA agreed with three of
our four recommendations. SBA disagreed with our recommendation to
consider incorporating policies and procedures into SBA's program
examinations for evaluating if a HUBZone firm is complying with the
performance of work requirements by expending at least 50 percent of
the personnel costs of a contract on its own employees. SBA stated that
although this requirement is included in SBA HUBZone regulations, it is
not a criterion for HUBZone program eligibility but rather a mandatory
contract term. SBA stated that contracting officers are required by the
FAR to insert such clauses regarding subcontracting limitations. While
we recognize that contracting officers have a responsibility for
monitoring the subcontracting limitation, SBA also has this
responsibility. In order to receive HUBZone certification, a firm must
certify to SBA that it will abide by this performance requirement, and
SBA is required by statute to establish procedures to verify such
certifications. Therefore, we continue to believe that SBA should
consider incorporating policies and procedures into its program
examinations for evaluating if a HUBZone firm is meeting the
performance of work requirements.
Madam Chairwoman, this concludes my statement. I would be pleased to
answer any questions that you or other members of the committee may
have at this time.
Contacts and Acknowledgments:
For further information about this testimony, please contact Gregory D.
Kutz at (202) 512-6722 or kutzg@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this testimony. In addition to the individual named above,
Bruce Causseaux, Senior Level Contract and Procurement Fraud
Specialist; Matt Valenta, Assistant Director; Erika Axelson; Gary
Bianchi; Donald Brown; Bruce Causseaux; Eric Eskew; Dennis Fauber;
Craig Fischer; Robert Graves; Betsy Isom; Jason Kelly; Julia Kennon;
Barbara Lewis; Olivia Lopez; Jeff McDermott; Andrew McIntosh; John
Mingus; Andy O'Connell; Mary Osorno; and Chris Rodgers also provided
assistance on this testimony.
[End of section]
Footnotes:
[1] GAO, HUBZone Program: SBA's Control Weaknesses Exposed the
Government to Fraud and Abuse, [hyperlink,
http://www.gao.gov/products/GAO-08-964T] (Washington, D.C.: July 17,
2008).
[2] GAO, Small Business Administration: Additional Actions Are Needed
to Certify and Monitor HUBZone Businesses and Assess Program Results,
[hyperlink, http://www.gao.gov/products/GAO-08-975T] (Washington, D.C.:
July 17, 2008).
[3] Firms that participate in the program generally must meet certain
requirements, including (1) at least 35 percent of its employees must
live in a HUBZone, (2) the principal office (i.e., the location where
the greatest number of qualifying employees perform their work) must be
located in a HUBZone, and (3) once a firm receives a HUBZone contract,
the firm is required to abide by certain subcontracting limitations.
[4] GAO, HUBZone Program: Fraud and Abuse Identified in Four
Metropolitan Areas, [hyperlink, http://www.gao.gov/products/GAO-09-440]
(Washington, D.C.: Mar. 25, 2009).
[5] These 19 firms had principal offices in or near four metropolitan
areas: Dallas, Texas; Huntsville, Alabama; San Antonio, Texas; and San
Diego, California.
[6] These 19 firms received a total of $187 million in federal
obligations in fiscal years 2006 and 2007.
[7] See 13 C.F.R. § 126.700.
[8] GAO, Small Business Administration: Additional Actions Are Needed
to Certify and Monitor HUBZone Businesses and Assess Program Results,
[hyperlink, http://www.gao.gov/products/GAO-08-643] (Washington, D.C.:
June 17, 2008).
[9] Internal controls comprise the plans, methods, and procedures used
to meet missions, goals, and objectives and also serve as the first
line of defense in safeguarding assets and preventing and detecting
errors and fraud. Fraud prevention, on the other hand, requires a
system of rules, which, in aggregate, minimize the likelihood of fraud
occurring while maximizing the possibility of detecting any fraudulent
activity that may transpire.
[10] GAO, Hurricanes Katrina and Rita Disaster Relief: Prevention is
the Key to Minimizing Fraud, Waste, and Abuse in Recovery Efforts,
[hyperlink, http://www.gao.gov/products/GAO-07-418T] (Washington, D.C.:
Jan. 29, 2007), and Individual Disaster Assistance Programs: Framework
for Fraud Prevention, Detection, and Prosecution, [hyperlink,
http://www.gao.gov/products/GAO-06-954T] (Washington, D.C.: July 12,
2006).
[11] As of February 2009, 7 of the 10 firms were still HUBZone
certified, according to SBA's Dynamic Small Business Web site. One of
the 2 firms in the process of being removed was no longer listed as
HUBZone certified.
[12] [hyperlink, http://www.gao.gov/products/GAO-08-964T].
[13] A firm that SBA has decertified may seek certification no sooner
than 1 year from the date of decertification. If the firm was
decertified for failure to notify SBA of a material change affecting
its eligibility, it must include with its application for certification
a full explanation of why it failed to notify SBA of the material
change.
[End of section]
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