Detailed Information on the
Intermediary Relending Program Assessment

Establish new baselines and ambitious targets once RBS has finalized the new measurement methodology for job creation. (This action has been modified due to program development, it now focuses on new efficiency measures, and better baselines and targets)

Implementing SEBAS evaluation program which gathers more precise and meaningful information on how program funds are used in rural communities and the ripple effect in the region.

Measure: Increase economic activity as measured by GDP in rural counties using program tool.

Explanation:Increase in employment is important but not the total impact. GDP change is a more reliable long term measure. This sophisticated evaluation measurement tool: Socio-Economic Benefit Assessement System,(SEBAS),was supposed to have been implemented by FY2006, unfortunately the program has hit some hurdles. Once up and running on a date TBD, SEBAS will model each rural county's unique economy (using mostly DOL and BEA information) and computes the local, regional and state economic impact of IRP investments. SEBAS requires slightly more detailed and descriptive data for each IRP investment. SEBAS will provide a state of the art analysis of such things as GDP contribution, job creation, quality of jobs created, and contributions to local taxes. Part of the SEBAS program includes cohort reviews in subsequent years to identify the "staying power" of jobs created and other long term impacts.

Measure: Cost per job, i.e cost to taxpayers for each job created/saved. (This measure is still Under Consideration/Review)

Explanation:The measure captures the cost to taxpayers for each job created/saved. To calculate this value, USDA will use the SEBAS program, which is still currently under evaluation. The SEBAS program will allow the agency to compute total funds invested and life cycle costs, including identifying leveraged monies that IRP funds attract. As most rural IRP agencies administer a basket of funds, the methodology for linking specific costs associated with IRPs to outcomes needs to be fully developed.

Measure: Increase in employment by looking at the cost to taxpayers for each job created/saved.

Explanation:cost to taxpayers for each job created/saved. Funding is in dollars.

Measure: The cost per job created and GDP improvement.

Explanation:Total cost to taxpayers for each job created/saved and improvement in GDP captures more fully the efficient use of taxpayer funds. Once up and running, the SEBAS model for each rural county's unique economy (using DOL and BEA information) will compute GDP contribution attributed to IRP investments. GDP will be computed for the local, regional and state level. SEBAS will provide a state of the art analysis of both GDP contribution and job creation. With a fuller understanding and description of the jobs created and GDP improvements the computation of costs per job created will be more meaningful.

Measure: Delinquency rate (Number of loans delinquent over number of total loans outstanding)

Explanation:Number of loans delinquent over number of total loans outstanding

Is the program purpose clear?

Explanation: As published in the Federal Register on February 6, 1998 (revised), RD Instruction 4274-D specifically states that the purpose of the IRP is to alleviate poverty and increase economic activity and employment in rural communities through financing targeted primarily towards smaller and emerging businesses. This purpose is achieved through loans made to intermediaries, in partnership with other public and private resources, and in accordance with State and regional strategy based on identified community needs, that establish programs for the purpose of providing loans to ultimate recipients for business facilities and community development in a rural area.

Evidence: The program is authorized in Section 623(a) of the Community Economic Development Act of 1981, as amended (42 U.S.C. 9812(a)). The mission of the Rural Business-Cooperative Service is to "enhance the quality of life for rural Americans by providing leadership in building competitive businesses including sustainable cooperatives that can prosper and grow in the global marketplace," RD Instruction 4274-D at http://frwebgate2.access.gpo.gov

Does the program address a specific and existing problem, interest or need?

Explanation: The IRP addresses the need for gap financing for many rural small businesses. These businesses oftentimes lack the necessary capital, credit, collateral, etc. to obtain conventional loans from banks and other lending institutions. Economic decline in rural areas has also limited the access and availability of rural capital. The IRP is often referred to as the lender of last resort. The assistance should ultimately strengthen the ultimate business in becoming self-sustaining and obtaining conventional financing on its own.

Evidence: Revolving Loans for Rural America, A History and Assessment of the Rural Development Loan Fund and the Intermediary Relending Program, by the Center for Community Change and Rapoza Associates published in 1993. USDA Economic Research Service (ERS) "Rural America at a Glance, Rural Development Research Report No. RDRR97-1, September 2003," USDA Economic Research Service "Rural Industry; What do earnings trends tell us about the rural economy?, December 15, 2003, and the Electronic Report from the Economic Research Service "Comparisons of Metropolitan-Nonmetropolitan Poverty During the 1990s, Rural Development Research Report Number 96, June 2003.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: Numerous programs serve to stimulate economic development in rural communities. These include: the Economic Dev. Adm. (Economic Adjustment Assistance- RLF); the Health and Human Services (Community Services Block Grant); the Community Development Financial Institutions (CDFI) Fund (Core Component); and the Small Business Administration (Microloan Program). These agencies primarily serve metropolitan areas, but can serve all areas. However, rural areas have been historically left behind by these other program, which is why Congress gave authority to the USDA Rural Development (RD) Agency to meet serve a niche by providing funds and needed services to all rural residents and providing a foundation on which sustained economic development can occur in rural America. However, without the IRP program, investment in economic development would still continue both through other Federal programs, including others within USDA, as well as various state programs.

Evidence: Catalog of Federal Domestic Assistance (CDFA), Small Business Financial Resource Guide, and 7 CFR 4274-D (Final rule dated February 6, 1998), Rural America, "Understanding Rural Population Loss" Volume 17, Issue 4/Winter 2002

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The IRP helps increase economic opportunity and improving quality of life in under-served areas. Without the IRP proceeds to establish or recapitalize the RLFs, the EDAs, CDCs, etc. would be deprived of an affordable lending pool upon which to assist the ultimate rural businesses. The IRP is offered at a rate of 1% per annum for a term not to exceed 30 years. It is the subsidized interest rate that makes up almost the entire subsidy cost of this program. The intermediary assumes responsibility for its debt service to the Agency regardless of whether to ultimate business is timely in its fudiciary obligations to the intermediary. There are no defaults in the program. There are no fees associated with the program. The funds are leveraged with State, local and philanthropic funds to create a larger lending pool. Because of the difficulty in obtaining credit from conventional lending sources, the IRP facilitates this funding need by providing credit for projects and thereby meeting the program's policy objectives of stimulating econonmic development in rural communities.

Evidence: Section 623(a) of the Community Economic Development Act, Federal Register: February 6, Volume 63, Number 25, RD Instruction 1951-O which provides policies and procedures for servicing direct financial assistance when it is determined that a borrower was not eligible for financial assistance received. Federal Credit Supplement.

Is the program effectively targeted, so that resources will reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: The IRP is specifically targeted to rural areas, and the ultimate business must be located in a city of less than 25,000 population. It is prioritized to meet the communities of greatest need based on low household income, areas with high unemployment rates, assisting members of underrepresented groups, and areas suffering from outmigration. The appropriation of IRP monies include earmark funds setaside for businesses located in Empowerment Zones/Enterprise Communities and Rural Economic Area Partnership (EZ/EC/REAP), Native American and Mississippi Delta designated areas.

Evidence: 7 CFR 4274.344(c), As evidenced in RD Instruction 1940-L, as authorized by the 2004 appropriations bill, the setaside for EZ/EC/REAP was $5.62 million (14% of total loan level); Native American was $3.5 million (9% of the total loan level); and Mississippi Delta $7.1 million (18% of total loan level).

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: L/T measures focus on key outcomes of the program: increase in economic activity and employment in rural communities. Intermediaries must provide the proposed number of jobs to be created/saved at the application stage. Quarterly submissions of Form RD 1951-4 capture detailed information about the financial operations of the intermediary and summarize the activity of ultimate recipients. It's currently being enchanced to capture job verification dates, number of jobs prior to loan, and cost per job created. RBS anticipates its completion by early 2005. Annual visits are conducted by the Agency and job counts/verification dates are entered in GLS. RBS has contracted with the University of Missouri to help capture the total effect of RD programs on rural America. This study will assist in measuring the quality of jobs and how industries in a region link. The study will help the Agency to ascertain where a particular business is getting its material, etc. and what other industries are benefitting from a business.

Evidence: USDA Strategic Plan for FY 2002-2007, Rural Development Strategic Plan for FY 2006-2011

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: RBS is currently revising its job creation measure for this program. They will be switching from a formula based job factor to actual job creation assessments and projections. RBS has an IRP Direct Final Rule underway that will include an amendment to measure cost per job. This will be calculated by dividing the program budget authority obligated by the number of jobs. This is a more reliable measure and is verifiable in GLS. The Agency anticipates this will be in effect beginning FY 2005. Also, when Business Programs Assessment Reviews (BPAR's) are conducted, the job information in GLS is verified though representative sampling.

Evidence: RD Instruction 4274-D, Business Programs Assessment Reviews (BPAR's), RBS' Guaranteed Loan System (GLS), Intermediary Relending Program Housekeeping RIN# 0570-AA42 Workplan number RBS 01-001

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The current practice of using a factor to identify the targeted goal, results in the program always reaching its goal if the antipated funding is appropriated. OMB agrees with job creation as an appropriate measure. The Agency is currently working with OMB and other USDA Agencies to develop some common ways to measure efficiency of USDA credit programs. Additionally, RBS has contracted with the University of Missouri to help capture the total effect its business programs on rural America. This should help identify better annual measures as well as long-term goals, and, as noted, the job crreation measure is being revised. At this time the current approved measure is under review/revision.

Evidence: Rural Development 2006 Stragic Plan, GLS, USDA Strategic Plan for FY 2002-2007, Budget Performance Integration. Study commissioned with the Univ. of Missouri.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: Once the new job creation measure is in place, verification and follow-up will occur through the State/field offices annual borrower visits to ensure proper usage of funds and verify job information. These numbers will be further verified in the RBS's Guaranteed Loan System (GLS). Annual measures will be based on cost per job created and/or saved. These figures will be based on actuals reported from previous years and then extrapolated to determine targets. This method of measurement will allow for monitoring actual performance rather than using the old methodology, that involved a research formula, which yielded mechanical results. Baselines and ambitious targets will be the result of this change.

Evidence: GLS, Form RD 1951-4, "Report of IRP/RDLF Lending Activity," BPARs

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: Through IRP regulations, debt instruments, and closing documents, the borrower is determined to be credit worthy and must agree to annual reporting requirements, which include job information. IRP borrowers are required to submit quarterly reports which is a tool used by the Agency to collect job information. Also, as part of the application, the borrower is required to submit a workplan that addresses goals and outcomes that would include the number of anticipated jobs created/saved. This document must be approved by the Agency.

Evidence: 7 CFR 4274-D and 1951-R, Form RD 1951-4, "Report of IRP/RDLF Lending Activitiy"

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: RBS has contracted with the University of Missouri to help cature the total effect of RD business programs on rural America. This study will assist in measuring the quality of jobs and how industries in a region link. The study will help RBS to ascertain where a particular business is getting its material, etc. and what other industries are benefitting from a business. In addition, the Special Projects/Programs Oversight Division conducts State Office Business Programs Assessment Reviews (BPAR) as a management tool to identify weaknesses in State internal controls, program administration, lender oversight, program outreach, and management information systems. An OIG audit was conducted in 12/00 to review selected intermediary's overall administration of an IRP revolving loan fund. An IRP Management Control Review (MCR) is scheduled for FY 2005 to ensure RBS compliance with all applicable Civil Rights Laws, Executive Orders and program requirements.

Evidence: BPAR, OIG Audit Report No. 85099-1-SF, Management's Discussion and Analysis of Rural Developments Consolidated Statements 2004, University of Missouri Study

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Currently, budget requests are submitted with explanatory notes that are related to program performance results, but the notes do not give a clear indication of the full cost of achieving the results. However, the Agency is meeting with OMB and other USDA agencies to determine common efficiency measures to ensure annual and/or long-term goals are met.

Evidence: The FY 2005 Budget Performance Integration process will require a great effort to tie the Budget request to program performance.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: RBS recognizes the deficiency in the performance measures in this program being based on a multiplier. In an effort to improve these measures so that they can improve their strategic planning, RBS has contracted with the University of Missouri to capture the total effect of RD programs on rural America. This will ultimately assist in quantifying increase in economic activity (increase in rural capital base.)

Evidence: Study with the the University of Missouri on RBS program performance.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Borrowers, which are considered partners in economic development, are required to submit audit reports, quarterly/semiannual reports of lending activity (which include the intermediary's income and expenses, financial condition, and a summary of names and characteristics of the ultimate recipients the intermediary has financed) and annual proposed budgets. Delinquencies are monitored on a quarterly basis. The Agency conducts annual lender reviews where feedback is obtained from constituent groups. In addtion to these efforts, a Direct Final Rule is underway to address concerns and deficiencies identified by RBS/State Office personnel and provide clarity and flexibility in the way the program is administered. The Agency has issued an Administrative Announcement to the States concerning RBS compliance with applicable Civil Rights laws, Executive Orders, and program requirements. In order to ensure that all program requirement are met, the Agency is obligated to complete Civil Rights Reviews before loan closing and every 3 years thereafter on all relending programs.

Evidence: Form RD 1951-4, "Report of IRP/RDLF Lending Activity," which is received by the timetables established in 7 CFR 4274-D and 1951-R, BPARs, MCR 2000, GLS, RD AN No. 3876

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Program Directors are rated on performance in processing and servicing of IRP loans. States not meeting regulatory requirements for sound underwriting and servicing may have its authority removed and/or receive training in the areas of deficiency. Program recipients are held accountable for prudent loanmaking and servicing activities based on, an agreed upon, Letter of Conditions (LOC), workplan, and signed request of obligation of funds. The condition of approval is based on the borrowers commitment to these requirements.

Evidence: 7 CFR 4274-D and 1951-R, 2006-I, 1901-A

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: IRP funds are appropriated by Congress on an annual basis. The appropriation law requires that dollars must be obligated prior to the end of the Fiscal Year in which they are allocated. The State/field offices ensure that funds are used for eligible loan purposes as evidenced in the LOC, workplan, RLF Agreement, debt instruments, and the Form RD 1940-1. These are signed legally-binding documents that must be adhered to in order for the borrower to close on the Agency loan. Program regulations require that the borrower have an ultimate recipient approved and ready for closing prior to closing the Agency loan. IRP borrowers can only apply for an amount of funding that can be advaned to ultimate recipients within 1 year of closing. The workplan must document proposed businesses to be assisted. Subsequent applications are not eligible to be considered for funding until 80% of each prior loan is advanced.

Evidence: RD Instruction 1940-L, Exhibit A, Attachment 1, which provides RBS loan and grant funding allocations for any given fiscal year, and procedures for accessing National Office reserve funds, pooling & funding cycle dates, and required obligation dates, GLS, 7 CFR 4272-D and 1951-R, Finance Office Report 205-C

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: RBS is amending RD Instruction 4274-D to require that the borrower have an ultimate recipient loan approved and ready to close prior to closing. USDA loan programs are also developing a consistent efficiency measure, which will apply to this program. Also, RBS is researching the cost/benefits to developing new web-based system Rural Utilities Loan Servicing System (RULSS) that will handle obligations, notes, advances, mergers, consolidations, and transfers. Future enhancements will include billings and collections. This way of reporting will allow a greater ease in monitoring borrower activities and result in savings of time and resources. Additionally, as with all loan programs, the S&E costs associated with this program are appropriated to the IRP account to show the subsidy and the loan costs all in one place.

Evidence: 7 CFR 4274-D Federal Credit Reform Act: requires S&E for loan programs be reflected in the loan program account.Rural Development Fiscal Years 2003 and 2004 Annual Performance Plans

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program has joint goals with other USDA/Federal agencies to target small businesses. The IRP has leveraging that occurs on two levels - the borrower may contribute funds to be part of the RLF (as Agency security for the loan), and the borrower and/or outside sources can contribute funds toward total project costs. This leveraging oftentimes comes from other Federal/State/local funds that share similar missions. The IRP complements other programs and has been a popular lending source for rural America.

Evidence: 7 CFR 4274.344(c)(1)(i),(ii),and (3) IRP Paperwork Burden Package

Does the program use strong financial management practices?

Explanation: The Agency contracted with American Bankers Association to develop a training CD ROM (Analyzing Financial Statements) to ensure compliance with sound financial management practices. Borrowers are required to submit audit reports at the end of an audit period. Audits must cover all of the intermediary's activities and must be performed by an indpendent certified public accountance. Acceptable audits are performed in accordance with Generally Accepted Government Auditing Standards.

Evidence: 7 CFR 4274.338(b)(4)(i), Rural Business-Cooperative Service Analyzing Financial Statements, Form RD 1951-4, "Report of IRP/RDLF Lending Activity"

Has the program taken meaningful steps to address its management deficiencies?

Explanation: IRP regulations were amended to clarify and revise procedures and requirements regarding a variety of issues. The amendments have clarified the roles of the Government and intermediaries, made the program more responsive to the needs of intermediaries and ultimate recipients, and facilitates continuing expansion of the program.The Agency is working with developers to create a field in GLS to make system enhancements to better manage the proper application of late fees collected on the IRP portfolio. Also, RBS is researching the possibility of adopting a new web-based system Rural Utilities Loan Servicing System (RULSS) that will handle obligations, notes, advances, mergers, consolidations, and transfers. Future enhancements will include billings and collections. This way of reporting will allow a greater ease in monitoring borrower activities and result in savings of time and resources.

Evidence: USDA Office of Inspector General, Report No. 34601-001-TE, RULLS is under development

Is the program managed on an ongoing basis to assure credit quality remains sound, collections and disbursements are timely, and reporting requirements are fulfilled?

Explanation: The Agency has hired a contractor to develop an IRP self-instructional CD ROM that will address underwriting criteria to ensure quality loans. All program recipients are encouraged to take advantage of Pre Authorized Debt (PAD) to ensure that loan payments are electronically drawn from the RLF deposit account. This process eliminates the possibility of late fees accruing on accounts. The borrower is required to provide the RLF deposit account number, routing number and bank information in order for advances to be made by the Agency. Borrowers must commit, in writing, to reporting requirements prior to loan closing. Borrower visits are conducted annually, whereby reporting information is verified and the Agency ensures that IRP proceeds are being used for an approved purpose. Existing regulations require qualified personnel to administer the program.

Evidence: BPARS, 7 CFR 4274-D and 1951-R, Form RD 1951-4. The Federal Credit Supplement

Do the program's credit models adequately provide reliable, consistent, accurate and transparent estimates of costs and the risk to the Government?

Explanation: The IRP uses historical data on portfolio performance to develop subsidy rates. Information is extracted from GLS for budget formulation. The subsidy rate is formulated, re-estimated, and apportioned within all OMB guidelines. The magnitude of change in subsidy re-estimates is modest, within the last year the actual cost of the program has decreased (FY '04 43.27 vs. FY '03 48.26) due to a low percentage of defaults.

Evidence: USDA Rural Development Budget Summary. The Federal Credit Supplement.

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The number of jobs created or saved have historically been achieved successfully. Actual jobs created and/or saved are subject to the availability of funds appropriated by Congress. Years in which performance goals weren't met has been due to a decrease in budget authority. Also, a Request for Automation is in place to create a field to capture actual jobs created and/or saved in GLS. However, these measures are being revised because they are based on a factor. The new measure will provide much better information on how well we are achieving our long term goals.

Evidence: FY 2003 & 2004 Annual Performance Plan, Report Code 205C, Annual Program Performance Reports, Funds Advanced Report.

Does the program (including program partners) achieve its annual performance goals?

Explanation: Over the last three years, on average, the Agency has exceeded its annual performance goals. The delinquency rate has consistently remained low thereby decreasing the Federal government risk of loss. An IRP Direct Final Rule is underway that will include an amendment to measure cost per job. This will be accomplished by dividing the amount of budget authority obligated by the number of jobs created and/or saved. Also, the Form RD 1951-4 is being enhanced to capture vital information regarding the applicants financial operations and ultimate recipient activities (including job validation, etc.) However, since the main job creation measure is being revised these facts provide only a small amount of information in order to evaluate the programs current success on an annual basis.

Evidence: Annual Performance Plan 2003 & 2004, Business Programs Annual Report FY 2003, Form RD 1951-4, "Report of IRP/RDLF Lending Activity" Federal Credit Supplement

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The subsidy rate, which measures the cost of the program, has decreased in FY '04 from FY '03 (43.27 and 48.26 respectively.)

Evidence: USDA Rural Development Budget Summary. Federal Credit Supplement

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The program has joint goals with other USDA/Federal agencies to target small businesses. The IRP has leveraging that occurs on two levels - the borrower may contribute funds to be part of the RLF (as Agency security for the loan), and the borrower and/or outside sources can contribute funds toward total project costs. This leveraging oftentimes comes from other Federal/State/local funds that share similar missions. The IRP complements other programs and has been a popular lending source for rural America. However, unitl RBS can measure how many jobs we are actually creating or saving through this program, our ability to compare with other programs with like goals is limited at best.

Evidence: 7 CFR 4274.344(c)(1)(i)(ii) and (3), GLS, Rural Development Annual Performance, FY 2002 & 2003, Business Programs Annual Results, FY 2002 & 3003

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: RBS has a Special Projects/Program Oversight Division (SPPOD) that conducts independent State Office reviews of business programs activities called Business Program Assessment Reviews (BPAR). The monthly BPARs are conducted to identify weaknesses in State internal controls, program administration, lender oversight, program outreach, and management information systems. These findings are brought to the attention of State staff as a means to correct deficiencies and reverse wrong-doings. Annual Managements's Discussion and Analysis of RD Consolidated Statements are prepared that reflect target/actual Key Performance Indicators. These assessments ultimately lead (as has been exemplified on more than one occasion to OMB) to the improvement of program regulations and procedures and the overall efficiency of State Office operations. Additionally, RBS has contracted with the University of Missouri to help cature the total effect of Rural Development business programs on rural America. This study will assist in measuring the quality of jobs and how industries in a region link. The study will help the Agency to ascertain where a particular business is getting its material, etc. and what other industries are benefitting from a business.

Evidence: BPARs, Borrower Visits, GLS, MCR 2000, OIG Audit Report No. 85099-1-SF December 2000, Form RD 1951-4, "Report of IRP/RDLF Lending Activity," Management's Discussion and Analysis of Rural Development's Consolidated Statements, University of Missouri Study