Audit of the Massachusetts Office of International Trade and Investment
June 30, 2022 · Massachusetts Office of International Trade and Investment · Read the full official report on mass.gov ↗
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“MOITI’s process for collecting and recording information about small businesses in underserved small business communities (USBCs) applying to STEP is ineffective.”
Read the plain-English breakdown
This is a state performance audit of the Massachusetts Office of International Trade and Investment, covering September 30, 2018 through June 30, 2021.
“In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of the Massachusetts Office of International Trade and Investment (MOITI) for the period September 30, 2018 through June 30, 2021.”
Auditors checked whether MOITI followed rules for STEP grants, including who got funding, what costs were reimbursed, what information was collected, and whether businesses were moved out of the program after enough support.
“In this performance audit, we determined whether MOITI graduated small businesses from the State Trade Expansion Program (STEP), whether it collected required information from small businesses to which it awarded funding through STEP, whether it ensured that the financial assistance awards it gave to small businesses were only for allowable activities, whether these activities were supported by adequate documentation, and whether the small businesses that were given financial assistance awards provided the required cash match.”
If MOITI does not track applicant information correctly, it cannot fully tell whether STEP is reaching underserved small business communities.
“As a result, MOITI’s ability to evaluate the effectiveness of its efforts to promote STEP to USBCs is limited.”
For residents and small business owners, the issue is whether public grant money is being managed fairly and whether new small businesses get a real chance to benefit.
“Further, implementing graduation requirements would create opportunities for new small businesses to receive financial assistance awards.”
MOITI said it would update its application, train staff, review records, and create a plan for transitioning businesses out of STEP starting with fiscal year 2023 STEP 11.
“MOITI will implement a STEP Transition Plan, per the audit recommendation starting with FY 2023 STEP 11 (the FY 2022 STEP 10 proposal has already been submitted to the SBA).”
The stakes include future federal funding, because poor administration could hurt MOITI’s ability to get STEP money from the SBA later.
“Not effectively administering STEP could negatively affect MOITI’s ability to secure future STEP funding from SBA.”
STEP is a grant program meant to help small businesses pay some costs of entering or expanding into international markets.
“STEP helps small businesses overcome obstacles to exporting by providing grants to cover costs associated with entering and expanding into international markets.”
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What the Auditor checked
- Did not comply Did MOITI collect information about the four designated underserved small business communities (USBCs) discussed in Section 1.4 of the federal Small Business Administration’s (SBA’s) STEP Funding Opportunity Announcement OIT-STEP-2018-01 and “Questions and Answers (Q & A) in Response to OIT STEP-2018-01”?
- Did not comply Did MOITI graduate small businesses from STEP after they had spent a reasonable time in the program and obtained a reasonable amount of funding, as encouraged by Section 5.2 of STEP Funding Opportunity Announcement OIT-STEP-2018-01?
What the Auditor found
Why it matters: MOITI’s ability to evaluate outreach to underserved small business communities was limited, SBA reporting may have been incomplete or inaccurate, and future STEP funding could be negatively affected.
Standard: Section 1.4 of SBA’s STEP Funding Opportunity Announcement OIT-STEP-2018-01 and SBA’s “Questions and Answers (Q & A) in Response to OIT-STEP-2018-01.” ( Section 1.4 of SBA’s STEP Funding Opportunity Announcement OIT-STEP-2018-01; Questions and Answers (Q & A) in Response to OIT-STEP-2018-01 )
4 recommendations
- MOITI should review the information it has for businesses that have received STEP financial assistance awards regarding their statuses as part of USBCs and correct any inaccurate information.agency: agreed
- MOITI should ensure that its employees are aware of the requirements of STEP.agency: agreed
- MOITI should revise its Massachusetts STEP Program Readiness Assessment and Application to include SBA’s definitions of the four USBCs and an area where a small business should document any of the four USBCs to which it belongs.agency: agreed
- MOITI should implement monitoring controls to ensure that it accurately records applicants’ reported USBC statuses on its PPRs.agency: agreed
Agency response & Auditor reply
Agency: "That said, MOITI does not dispute the audit’s recommendations will improve administration of the STEP program and result in increased effectiveness of MOITI’s internal controls including employee training/education and monitoring controls."
Auditor: "Based on its response, MOITI is taking measures to address our concerns in this area."
Why it matters: Small businesses could receive financial assistance awards every year, become reliant on STEP funding, and reduce opportunities for new small businesses to receive awards.
Standard: Section 5.2 of STEP Funding Opportunity Announcement OIT-STEP-2018-01. ( Section 5.2 of STEP Funding Opportunity Announcement OIT-STEP-2018-01 )
1 recommendation
- MOITI should implement requirements for graduating small businesses from STEP.agency: agreed
Agency response & Auditor reply
Agency: "MOITI concurs with the Audit Finding that the SBA’s intention is for MOITI to transition small businesses from STEP once they have sufficient export experience."
Auditor: "Based on its response, MOITI is taking measures to address our concerns on this matter."