OFFICE OF INSPECTOR GENERAL

• Vision and Mission Statements
  

• Values
  
• Statutory Responsibilities
  
• Challenges Facing SBA and OIG
  
• Strategic Focus
  
• Summary of Goals and Objectives
  
• Goals, Objectives, Strategies, and Performance Measures
  
• Relationship between the General Goals and Objectives in the
      Strategic Plan and the Performance Goals in the Annual Plan
  
• Key External Factors
  
• Performance Evaluation
  
• Resources and Operational Responsibilities
  
• Data Collection and Verification
  
• Organizational Chart

VISION

Our vision is to improve SBA’s programs by identifying key issues facing the Agency, ensuring that corrective actions are taken, and promoting a high level of integrity. We will focus on serving the needs of our customers and stakeholders and on safeguarding SBA resources from waste, fraud, and abuse. We will also provide a work environment in the OIG that is conducive to excellent performance by our employees.

To accomplish this vision, we will –

· Focus on significant, systemic issues drawn from the cumulative results of our reviews and cases.

· Enhance our expertise in SBA’s major programs to help us identify priority issues and plan our reviews and casework.

· Become more proficient in the use of information technology, research methods, data analysis, and investigative techniques.

· Encourage creative thinking within our office and the development of synergistic teams that combine various disciplines.

· Achieve superior results by emphasizing corrective actions that will improve SBA operations, combat fraud, and eliminate program vulnerabilities.

 

OIG MISSION

Under the authority and in fulfillment of the Inspector General Act of 1978, as amended (IG Act), the Inspector General is committed to supporting the Small Business Administration (SBA) in its statutory mission to maintain and strengthen the Nation's economy by aiding, counseling, assisting, and protecting the interests of small businesses and by helping families and businesses recover from disasters.

 

VALUES

Respect for the Individual: We recognize that people are our most important resource. The dignity, personal well-being, and professional development of our employees is of paramount importance for accomplishing our mission. We seek to promote a work environment that is free of prejudice and discrimination, and values diversity. We encourage creativity and reward exemplary performance.

Excellence and Effectiveness: We strive to be efficient and results-oriented, taking personal responsibility for the quality of our work. Our activities are designed to provide our stakeholders with the highest possible level of useful, timely, and responsive service.

Professionalism and Integrity: We adhere to the highest standards of ethical behavior. How we achieve results is as important as the results themselves. We promote integrity, credibility, professionalism, and accountability in our employees.

Independence and Objectivity: We maintain the freedom and impartiality necessary to objectively and responsibly perform our mission. We accommodate honest differences of opinion, but we cannot accommodate the compromise of principle.

Communication: We strive for an environment of open and honest communication internally and externally. We listen to, learn from, and collaborate with our employees and stakeholders.

Teamwork: We work as a team and challenge our employees to work cooperatively across internal and external organizational boundaries. We involve employees at all levels in developing and continually improving our work processes and encourage responsible risk-taking (e.g., criticism, debate, dissent) as a fundamental operating principle.

Accountability: We are committed to serving as effective and responsible stewards of the taxpayers' dollars. We believe in providing employees with a clear understanding of what is expected of them and with the guidance needed to perform their tasks. Each individual is responsible for her/his actions. Managers are responsible for ensuring that work is fairly evaluated and appropriately recognized.

STATUTORY RESPONSIBILITIES

The Office of Inspector General (OIG) is an independent and objective oversight office created within the SBA by the IG Act. The Act specifies that the Inspector General will:

· Promote economy, efficiency, and effectiveness in the management of SBA programs and supporting operations;

· conduct and supervise audits, investigations, and reviews relating to the Agency's programs and supporting operations;

· detect and prevent fraud and abuse;

· review existing and proposed legislation and regulations and make appropriate recommendations;

· maintain effective working relationships with other Federal, State, and local governmental agencies, and non-governmental entities regarding the mandated duties of the Inspector General;

· inform the SBA Administrator and Congress of serious problems and recommend corrective actions and implementation measures;

· comply with the audit standards of the Comptroller General; avoid duplication of General Accounting Office (GAO) activities; and

· report violations of law to the U.S. Attorney General.

OIG also has other significant statutory responsibilities. They include responsibilities under the Small Business Act of 1958, the Small Business Investment Act of 1958, the Federal Managers' Financial Integrity Act of 1982, the Chief Financial Officers Act of 1990, the Right to Financial Privacy Act, the Freedom of Information Act, and the Privacy Act. These responsibilities are carried out by five divisions: Auditing, Inspection and Evaluation, Investigations, Legal Counsel and Management and Policy.

 

CHALLENGES FACING SBA AND OIG

SBA provides financial, contracting, technical and management assistance to small businesses. The OIG plan is based primarily on the financial risk of SBA loans to the Government. It calls for more resources to be devoted to those SBA programs and operations representing the greatest financial exposure and fewer resources for those programs that carry a lower risk. A major risk to the Government is the potential loss inherent in the SBA business and disaster loan portfolios. The financial management and information management systems are key to reducing risk.

Facing increased risk due to significant reductions in Agency staff and budget in recent years, SBA is moving aggressively to modernize. This effort will present additional challenges both to SBA and to OIG in the areas of outsourcing, and information systems modernization. Key to maintaining the effectiveness, economy, and efficiency of SBA programs will be improving oversight of loan and other activities performed by private sector partners.

For some years SBA has used the services of a private Fiscal and Transfer Agent for its business loan programs. SBA has now piloted a contract with the private sector for the servicing of a portion of the disaster loan portfolio and is implementing an asset sales program to sell selected portions of the loan portfolio. Increasingly SBA is relying on credit decisions by lending partners through the 7(a) Preferred Lending Program (PLP), the LowDoc Program, SBAExpress, and the various tiers of the Certified Development Company Program.

Outsourcing and asset sales will make the OIG oversight task more complex. At the same time, SBA is undertaking an Agency-wide information systems modernization effort that will selectively overhaul key programmatic, financial, and management information systems and processes. The FY 2001-2006 strategic plan and the more detailed annual plans to follow are designed to meet these challenges.

STRATEGIC FOCUS

While this plan provides a number of strategies to accomplish our goals over the next 6 years, OIG will focus our work under each of our goals primarily on the following areas:

· Financial management systems;

· Information systems and computer security;

· Lender oversight;

· Other selected high risk issues; and

· New Agency initiatives.

We will also place a high priority on responding to requests from SBA management and congressional committees and providing consultative assistance where appropriate.

 

SUMMARY OF OIG STRATEGIC GOALS

Goal 1. Improve the economy, efficiency, and effectiveness of SBA programs and operations.

Goal 2. Prevent and detect fraud and abuse, and foster integrity in SBA programs and operations.

Goal 3. Ensure the economical, efficient, and effective operation of OIG.

FY 2001-2006

SBA OIG

GOALS, OBJECTIVES, STRATEGIES,

AND PERFORMANCE INDICATORS

Goal 1. Improve the economy, efficiency, and effectiveness of SBA programs and operations.

Objective 1.1 Conduct reviews of major program activities, with emphasis on high risk and high priority areas, and assess whether SBA can be reasonably assured that its programs are meeting their goals in an economical, efficient, and effective manner.

Strategies Conduct audits, inspections, and investigations to determine whether SBA's programs are meeting customer and stakeholder needs. Review performance planning and measurement activities under the Government Performance and Results Act, and other applicable laws, identify where improvements can be made, and make recommendations that will assist the Agency in meeting their goals. Use the COSO (Committee of Sponsoring Organizations) internal control framework and other evaluation methods to determine whether goals are being met efficiently and effectively. Review new rules, regulations, procedures and legislation, and provide recommendations on reasonableness and effectiveness. Participate in collaborative efforts with SBA program managers and staff (including Agency task forces) and explore opportunities for developing innovative products that can provide feedback or input to management on a expedited basis. Concentrate on the high risk programs if resources are not adequate to review all programs.

 

	Performance Indicators
	Output Indicators Percentage of all recommendations on major program activities accepted by management or otherwise resolved within 6 months of report issuance Narrative assessment of OIG contribution to Agency task forces	Intermediate Outcome Indicator Percentage of all recommendations from reviews of major program activities implemented or corrective actions taken by management within the timeframe agreed by OIG and management
		Outcome/Impact Identification and implementation by the Agency of corrective actions for major management and operating problems in SBA

 

Goal 1. Improve the economy, efficiency, and effectiveness of SBA programs and operations.

Objective 1.2 Audit contracts, grants, surety claims, and defaulted loans to determine whether the costs claimed are allowable.
Strategies Audit selected program participants and activities with higher risk of monetary loss, special requests, and early defaulted loans.
	Performance Indicators
	Output Indicators Percentage of all recommendations in audits of contracts, grants, surety claims, and defaulted loans accepted by management or otherwise resolved within 6 months of report issuance Percentage of dollars in questioned costs, funds to be put to better use, settlement recoveries, and cost corrective measures in audits of contracts, grants, surety claims, and defaulted loans accepted by management or otherwise resolved within 6 months of report issuance	Intermediate Outcome Percentage of all recommendations in audits of contracts, grants, surety claims, and defaulted loans implemented by management within the timeframe agreed by OIG and management

 

Outcome for Goal 1 OIG activities improve the economy, efficiency, and effectiveness of SBA programs Methodology for Measuring Outcome Estimate the impact of implemented recommendations, e.g., what percentage of corrective actions taken in response to the OIG recommendations resolved the identified problems and/or resulted in improved SBA programs or operations. Limitations: Because OIG staff and resources are limited and intervening variables may also make it difficult to draw direct causal relationships, a pilot for estimating impact will be developed in FY 2001. The pilot will assist us in determining the level of resources needed to evaluate impact. As SBA develops and verifies the accuracy of its performance measurement system, it may also be possible to use some of that information to assess OIG effectiveness.

Goal 2. Prevent and detect fraud and abuse, and foster integrity in SBA programs and operations.

Objective 2.1 Detect/identify waste, fraud, abuse, and integrity problems in SBA programs and operations and take appropriate action.
Strategies Investigate those cases with the highest impact and potential for successful criminal or civil prosecution, and refer others to SBA for administrative action or to other law enforcement agencies. Expand activities to pursue civil fraud under the False Claims Act.
	Performance Indicators
	Output Indicators Percentage of criminal cases referred that are accepted by the U.S. Attorneys Percentage of Affirmative Civil Enforcement (ACE) cases referred that are accepted by U.S. Attorneys	Intermediate Outcomes Percentage of monetary recoveries to actual losses Percentage of closed cases resulting in criminal, civil, or administrative actions

Goal 2. Prevent and detect fraud and abuse, and foster integrity in SBA programs and operations.

Objective 2.2 Prevent and deter fraud and abuse, and other misconduct through studies and education programs for employees and participants.
Strategies Provide assistance to SBA officials in developing their capacity to address program complaints or allegations of program abuse through alternatives to investigations, audits, and inspections, where appropriate. Increase the frequency and scope of OIG, SBA, and private sector partners' employee integrity/fraud awareness programs by disseminating fraud prevention information and guidance through seminars, periodic "fraud alert" bulletins, and other channels, as appropriate. Expand outreach to SBA's private sector partners to encourage them to report allegations. Periodically review the content and structure of OIG integrity briefings and presentations to Agency components to maximize their impact. Identify and report on substantial program weaknesses that may expose SBA to fraud, or abuse and recommend corrective actions. Proactively target program weaknesses and develop new techniques for identifying and preventing fraud by conducting studies of historical investigative data, pilot projects, and/or trend analyses that will identify SBA programs at greatest risk for financial fraud, waste, and abuse.
	Performance Indicators
	Output Indicators Number of SBA employees attending integrity briefings Number of private sector partners attending integrity briefings	Intermediate Outcome Percentage of target population reached by integrity briefings

Goal 2. Prevent and detect fraud and abuse, and foster integrity in SBA programs and operations.

Objective 2.3 Preclude persons not of good character from participating in SBA programs and employment.
Strategies Provide the agency with timely name and fingerprint checks for SBA program applicants. Develop targeted random sample reviews to determine the level of fraud in Agency programs and make appropriate recommendations. Assist the Agency in maintaining high employment standards by participating in pre-employment screening and providing the required background investigations for potential SBA employees. Encourage the Agency to use CAIVRS, the debarred listing, and other appropriate information sources to identify persons not of good character. Encourage the Agency to examine 100 percent of SBA Form 912s submitted with applications for assistance.
	Performance Indicators
	Output Indicator Narrative assessment of the work of the Office of Security Operations in conducting criminal background checks of SBA program partners and participants, and administering SBA applicant/employee/contractor background investigations

 

Outcome for Goal 2 SBA internal policies, procedures, and controls are strengthened and provide a deterrence for future wrongdoing. OIG activities lead to changes in SBA practices that effectively prevent fraud and abuse, and promote the integrity of SBA programs and operations. Methodology for Measuring Outcome OIG will assess the practicality and feasibility of developing evaluations of major investigative cases and related audits and inspections to estimate the impact on the prevention and deterrence of fraud, and abuse. In addition, as SBA develops and verifies the accuracy of its performance measurement system, it may be possible to use some of the information to indicate OIG effectiveness. Limitations: Evaluation efforts will be constrained by a lack of information on the extent of actual fraud and other misconduct in SBA's programs and operations.

Goal 3. Ensure the economical, efficient, and effective operation of OIG.

Objective 3.1 Provide the tools, services, and supportive work environment necessary to improve employee productivity.
Strategies Recruit, develop, and maintain a well-educated, diversified, and technically competent staff with the skills necessary to accomplish the OIG mission. Regularly assess staff development and training activities to identify long-term organizational and specific division/team requirements; develop a training curriculum establishing mandatory training courses for specific grade or working levels. Establish policies and standards for rewarding high-quality performance and recognizing exceptional efforts. Develop and maintain an effective OIG quality assurance program. Provide appropriate and timely legal advice, administrative services, budget development and execution, equipment, and supplies to maximize the effectiveness of personnel. Provide modern and secure computer technology, and information systems for OIG staff.
	Performance Indicators
	Output Indicators Percentage of staff that received the training established by OIG for their career needs. Percentage of employees provided the IT products necessary to do their jobs, as established by the OIG	Intermediate Outcomes Percentage of employees satisfied or very satisfied in annual employee surveys Achievement of unqualified opinions on audit's quality controls by external peer reviews

 

Goal 3. Ensure the economical, efficient, and effective operation of OIG.

Objective 3.2 Communicate and foster cooperation with all stakeholders, customers, and interested parties.
Strategies Maintain ongoing liaison with Agency officials and key congressional committees to elicit input on issues that should be addressed and determine their satisfaction with OIG products. Disseminate to stakeholders information on OIG activities, including findings, recommendations, significant observations, and investigative results, and respond to congressional, Agency, and public concerns, inquiries and requests for information. Actively participate in OIG and interagency task forces, other groups, and hearings that address cross-cutting issues (i.e., issues common among OIGs or shared by SBA and other agencies) where positive change in OIG operations and/or SBA programs could result from interagency efforts.
	Performance Indicators
	Output Indicator/Intermediate Outcome Narrative assessment that may include anecdotal results of ongoing contacts with customers and stakeholders, OIG work on PCIE and interagency projects, and/or customer satisfaction surveys

 

Goal 3. Ensure the economical, efficient, and effective operation of OIG.

Objective 3.3 Develop and maintain a planning process that will provide for effective monitoring of operations and identify opportunities for improvement.
Strategies Develop reliable ways to ensure that OIG is addressing all aspects of its legislatively mandated mission. Periodically assess the need for modifications to the OIG's strategic and annual plans. Develop and maintain an effective monitoring system for tracking progress on all OIG objectives. Conduct periodic surveys of recipients and users of OIG products to obtain relevant feedback for developing plans and assessing progress in accomplishing our mission.
	Performance Indicators
	Output Indicator/Intermediate Outcome Narrative assessment of the results of the OIG planning process

 

Outcome for Goal 3 An OIG staff that is fully supported with the tools, services, and direction necessary to be economical, efficient and effective, and works cooperatively and in a timely manner with customers and stakeholders Methodology for Measuring Outcome An analysis of the performance indicator results in each Annual Performance Report (beginning with the FY 2001 Report) should indicate if OIG is operating economically, efficiently, and effectively.

 

RELATIONSHIP BETWEEN THE GENERAL GOALS AND OBJECTIVES

IN THE STRATEGIC PLAN AND THE PERFORMANCE GOALS

IN THE ANNUAL PLAN

The general goals established in the OIG strategic plan are based on the SBA mission and the requirements of the IG Act. They provide the framework for the audit, inspection, evaluation, investigative, and support activities proposed in the OIG annual performance plans and in the more detailed internal operating plans. To establish the required linkage between the general goals and objectives in the strategic plan and the measures in the annual plan, the strategic plan contains objective, measurable and, where appropriate, quantifiable performance indicators. The annual performance plans will detail the annual performance goals that will help measure progress in meeting our strategic goals and objectives.

 

KEY EXTERNAL FACTORS

OIG has established objectives and performance measures that are directed toward insuring the quality of the work and customer service we provide to SBA and Congress. Nevertheless, there are a number of factors beyond our control that could affect our achieving the goals and objectives established in this plan.

1. Resources. A significant decrease in personnel or funding resources would adversely affect the achievement of our goals and objectives and increase the risk of loss to the government and, ultimately, to the American taxpayer.

2. Mandatory Requirements. There are a number of statutory requirements which impact our ability to meet workload requirements. In addition to those found in SBA's enabling legislation, these include the Federal Managers' Financial Integrity Act (FMFIA) of 1982, which requires OIG to render opinions on all FMFIA assurance letters; the Chief Financial Officers Act of 1990, which requires OIG to audit financial statements of all accounts and associated activities of each SBA office and activity; and the Freedom of Information and Privacy Acts, which require executive agencies to provide public and individual access to Federal agency records, subject to certain exemptions and exclusions.

3. Statutory Changes in SBA Programs. Any significant changes in the Agency statutory authority, e.g., the addition of programs, or the repeal or consolidation of programs, could require modification to the goals and objectives in this strategic plan.

4. Agency Control. The implementation of program and system recommendations or improvements is not within OIG control. The ultimate authority to make those determinations rests with the Agency.

5. Judicial and Administrative Proceedings. OIG cannot control the results of judicial or administrative proceedings that may affect the outcomes of OIG efforts. It is also not within our jurisdiction, authority, or responsibility to collect monetary sanctions imposed by the courts or the Agency (restitution, fines, penalties, debts, etc.) as a result of our reviews or investigations.

 

PERFORMANCE EVALUATION

While this strategic plan was developed based on SBA's statutory mission and on our responsibilities under the IG Act, we also took into consideration prior OIG audit, inspection, and investigation work, and the results of an OIG customer satisfaction Survey on Effectiveness and Impact issued in September 1994. We have also consulted [are in the process of consulting] stakeholder groups in the Agency and Congress.

Evaluating progress in meeting OIG output and intermediate outcome performance goals will be a continuous activity. Externally it will be monitored through customer and stakeholder feedback, and external peer review. The customers and stakeholders of OIG include (1) the Administrator and senior management of SBA, (2) the Congress, especially the Chairmen of the cognizant House and Senate committees and subcommittees, and (3) program participants. We may use surveys of customers and stakeholders as appropriate, as well as meetings and correspondence with them, to determine if we are addressing critical needs or if changes in strategies are necessary.

Internally OIG will track established performance measures in the Management Information System, use the operating plan quarterly review process, and conduct periodic employee surveys.

Evaluations of outcomes of OIG activities will be initiated in FY 2001. Resource constraints, however, will limit the number of evaluations accomplished. At the end of each year, OIG will also assess the impact of the evaluations completed on the allocation of resources. A pilot project for the outcome/impact of Goal 1—improving the economy, efficiency and effectiveness of SBA programs and operations—will evaluate on a periodic basis the outcomes of selected high risk or significant issue audits and inspections where SBA has implemented the majority of the recommendations.

Determining the outcome/impact of Goal 2—reducing fraud and abuse and fostering integrity in SBA programs and operations—may not be cost effective because there is no information available on the actual extent of fraud and other misconduct in SBA. That OIG efforts have strengthened SBA internal policies, procedures, controls, and practices, thereby deterring future wrongdoing, is likely to be a primarily subjective judgment based on results of the output indicators. In FY 2001 OIG will assess the practicality and feasibility of developing an evaluation process for estimating the overall impact of OIG work in protecting the integrity of SBA programs and operations.

As indicated previously, for Goal 3—ensuring the economical, efficient, and effective operation of OIG—an analysis of all performance indicator results in the Annual Performance Report should indicate if OIG is operating economically, efficiently, and effectively.

Outcomes for individual objectives will be evaluated separately. In determining the impact of OIG activities, it may also be possible to use SBA performance information as it is further developed and refined.

 

RESOURCES AND OPERATIONAL RESPONSIBILITIES

The OIG is composed of the immediate Office of the Inspector General, and the Auditing, Investigations, Inspection and Evaluation, Legal Counsel, and Management and Policy Divisions. In addition to headquarters staff, the OIG currently has audit staff in Atlanta, Chicago, Dallas, and Los Angeles, and investigative staff in Atlanta, Chicago, Dallas, San Francisco, Denver, Houston, Kansas City, Los Angeles, New York, Philadelphia, Seattle, and Syracuse.

· The Auditing Division performs financial and performance audits of SBA programs to promote their economy, efficiency, and effectiveness. This division performs both internal audits of the Agency's management of programs and external audits of its program participants.

· The Inspection and Evaluation Division conducts analyses to assess the impact, effectiveness and related performance issues of SBA programs and supporting activities. This division also performs "best practices" studies, management reviews, and client satisfaction surveys to assist SBA in improving its program efficiency and oversight.

· The Investigations Division conducts financial, program, and personnel investigations involving SBA employees and recipients, and maintains the OIG Fraud Line. The results of these investigations frequently provide the basis for civil or criminal prosecution by the Department of Justice or, as an alternative, administrative action by the Agency. The personnel security branch within this division administers the personnel background and name check program for the Agency.

· The Legal Counsel Division ensures compliance with professional standards issued by PCIE and the General Accounting Office. This Division also provides independent legal advice to OIG officials and staff; reviews proposed legislation, regulations, and standard operating procedures; provides subpoena and litigation assistance for all OIG activities; and processes Freedom of Information/Privacy Act requests.

· The Management and Policy Division supports office operations through internal planning, budget formulation and execution, information resources management, personnel, and other administrative services.

 

DATA COLLECTION AND VERIFICATION

Several years ago the OIG developed a Management Information System (MIS) for tracking its activities. In FY 1998, OIG began enhancing MIS by integrating it with other types of software, establishing an Executive Query System that will link all OIG division databases, and making the system secure. As the OIG refines its internal performance measurement system, additional improvements and modifications will be made in MIS.

As appropriate, quantitative data will be collected and stored in MIS. Much of the quantitative data proposed has been collected for several years. For some of the measures, baselines will need to be established in FY 2000. Monetary results will be reported at the time of management decision in accordance with OIG legislative requirements. SBA's Office of the Chief Financial Officer tracks actual collections. All qualitative data will be thoroughly documented.

 

Organizational Chart