Way back in 2019, the SBA’s Office of Inspector General (OIG) issued a report on the SBA’s (then named) All Small Mentor Protege Program. At that time the SBA OIG found that the SBA didn’t create effective controls to ensure mentor-protege application reviews and evaluations were made in accordance with the regulations and SBA did not make sure such reviews and evaluations measured program success. The SBA OIG gave the SBA a list of recommendations at that time to fix those issues. At the end of September 2026 (after giving SBA a seven-year window), the SBA OIG revisited its 2019 inspection of the SBA’s Mentor-Protege Program (MPP) and found there were some improvements, but still some issues with the MPP, especially regarding protege business plans.

The SBA OIG last month issued OIG Final Report 26-16, revisiting its 2019 review of the SBA’s MPP. The SBA OIG’s report did contain many positives, finding that the SBA since 2019 has “established processes to ensure that mentors are qualified for the MPP during both initial application reviews and annual evaluations” and the SBA has “implemented procedures to ensure that certify.sba.gov has the necessary functionality for program officials to conduct application reviews and evaluations.” Regarding mentor review, the initial OIG recommendation was that SBA “[d]evelop and implement application review and annual evaluation procedures to ensure mentors are qualified, including implementing mandatory use of the mentor certification form.” OIG now finds that “analysts performed procedures to verify the mentors’ qualifications and eligibility for the MPP” and that “on July 27, 2026, that they had just restarted reviewing and completing annual evaluations in July 2026.” So, this report seems to indicate that contractors applying to the MPP should now expect a fairly consistent review of mentor qualifications.

There were two items the SBA OIG noted needed additional work or discussion. SBA OIG wrote: “SBA did not maintain protege business plans during initial application reviews as required; therefore, we will reopen this recommendation”; and “SBA’s corrective actions to address [2019’s review] Recommendation 3 were not fully implemented.” However, the 2019 Recommendation 3 was that there was not enough staff to prioritize application and annual review processes, and SBA OIG now states “we will not reopen this recommendation, as management has resumed conducting annual evaluations, which we confirmed during our review.” So, in essence, in its review of how much SBA had progressed since the 2019 report, the OIG had one specific item it is issuing additional corrective action on: protege business plans (it did note it would keep an eye on SBA staffing and ability to review applications).

The main concern of OIG in its current review is that the SBA did not sufficiently review business plans during MPP application reviews. As OIG explains, SBA “procedures require that business plans be included in the initial application package” but “the 12 application files we reviewed lacked the required business plan for the protege.” SBA OIG asserts that “[r]eviewing and maintaining the protege’s business plan is required during application reviews for the analyst to ensure the mentor-protege agreement aligns with the MPP and the goals outlined in the protege’s business plan.” SBA OIG cites the reasoning for such a business plan is from the “Standard Operating Procedures of the Office of Business Development” (SOP 80 05 8). Due to this, the SBA OIG wrote that it is re-opening its 2019 recommendation 2, which is: “Develop and implement procedures to ensure quality and consistency in application reviews and annual evaluations, including maintaining adequate documentation to support completion of each step in the application review and annual evaluation process.”

Now, you may be thinking that all sounds like an internal SBA problem for SBA to address, but it does have impact on federal contractors. Specifically, the applicants to the MPP and possibly current MPP participants, as this is something which could arise in application review and yearly evaluations. Based on this OIG report, it can be assumed the SBA will be looking for and requesting explicit business plans for proteges going forward, which they will then use to ensure the Mentor Protege Agreement (“MPA”) aligns with the protégé’s business plan. Something which, as OIG noted, did not appear present in many applications.

The regulation for the SBA MPP, 13 C.F.R. § 125.9, does not mention a business plan. But the SBA’s MPA template does mention a business plan in multiple places. The SBA does have a site regarding how to “Plan your business” which has a subsection on how to write a business plan. Also, the SOP cited from the OIG report appears to be the citation to what was once the SBA’s public SOPs for its 8(a) Business Development Program (“8(a) Program”). So, this may indicate that the SBA wants a business plan similar to that required under the 8(a) Program. But the specific form or substance of the protege’s business plan is not clear from the OIG report.

This OIG report appears to continue a trend of the SBA’s MPP implementing or emphasizing additional requirements outside the regulations on applicants and participants (see our other blogs on expectations regarding formatting and hours in the MPA). This OIG Report covers a lot of ground in a few pages and displays how the MPP has added in different capabilities and changed since 2019. So those interested in the MPP should read this report (it also discusses reporting to congress and how the SBA will ensure consistent reviews). But one of the major takeaways is that contractors can now expect that the SBA may require business plans to be submitted with the MPA when applying to the program and likely check to make sure the business plan aligns with the assistance in the MPA. On the other hand, SBA does not always follow every OIG recommendation down to the letter. Of course, with all the changes and updates to the MPP over the years, be sure to reach out to federal contracting attorneys, like us, to assist with navigating the MPA and MPP if you find yourself looking into the program and considering whether you meet its requirements.

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