Small Business Mentor-Protégé Programs

Updated June 10, 2022

Congressional Research Service

https://crsreports.congress.gov

R41722

Small Business Mentor-Protégé Programs

Congressional Research Service

Summary

Mentor-protégé programs typically seek to pair new businesses with more experienced businesses

in mutually beneficial relationships. Protégés may receive financial, technical, or management

assistance from mentors in obtaining and performing federal contracts or subcontracts, or serving

as suppliers under such contracts or subcontracts. Mentors may receive credit toward

subcontracting goals, reimbursement of certain expenses, or other incentives.

The federal government currently has several mentor-protégé programs to assist small businesses

in various ways. For example, the Small Business Administration’s (SBA) Mentor-Protégé

Program is a government-wide program designed to assist small businesses in obtaining and

performing federal contracts. Toward that end, mentors may (1) form joint ventures with protégés

that are eligible to perform federal contracts set aside for small businesses; (2) make certain

equity investments in protégé firms; (3) lend or subcontract to protégé firms; and (4) provide

technical or management assistance to their protégés. The Department of Defense (DOD) Mentor-

Protégé Program, in contrast, is agency-specific. It is designed to assist various types of small

businesses and other entities in obtaining and performing DOD subcontracts and serving as

suppliers on DOD contracts. Mentors may (1) make advance or progress (installment) payments

to their protégés that DOD reimburses; (2) award subcontracts to their protégés on a

noncompetitive basis when they would not otherwise be able to do so; (3) lend money to or make

investments in protégé firms; and (4) provide or arrange for other assistance.

Other agencies also have agency-specific mentor-protégé programs designed to assist various

types of small businesses or other entities in obtaining and performing subcontracts under agency

prime contracts. The Department of Homeland Security (DHS), for example, has a mentor-

protégé program wherein mentors may provide protégés with rent-free use of facilities or

equipment, temporary personnel for training, property, loans, or other assistance. Because these

programs are not based in statute, unlike the SBA and DOD programs, they generally rely upon

preexisting authorities (e.g., authorizing use of evaluation factors) or publicity to incentivize

mentor participation. See Table A-1 for a summary comparison.

The SBA’s Mentor-Protégé Program is the most used federal mentor-protégé program. It

currently has 1,565 active mentor-protégé agreements.

This report provides an overview of the federal government’s various small business mentor-

protégé programs. All of these programs are intended to assist small businesses in performing as

contractors, subcontractors, or suppliers on federal or federally funded contracts, but the

programs differ in their scope and operations.

Small Business Mentor-Protégé Programs 
 
Congressional Research Service 
Contents 
Introduction ..................................................................................................................................... 1 
Mentor-Protégé Programs Administered by the SBA ..................................................................... 4 
Mentoring Networks Under the Federal and State Technology Partnership Program .............. 4 
Recent Developments ......................................................................................................... 5 
SBA’s Mentor-Protégé Program ............................................................................................... 5 
Mentor Requirements .......................................................................................................... 6 
Protégé Requirements ......................................................................................................... 6 
Written Agreements ............................................................................................................ 7 
Participant Benefits ............................................................................................................. 7 
GAO’s Reports and Legislative Action .............................................................................. 8 
DOD Mentor-Protégé Program ..................................................................................................... 10 
Mentor Requirements ......................................................................................................... 11 
Protégé Requirements ....................................................................................................... 12 
Written Agreements .......................................................................................................... 13 
Participant Benefits ........................................................................................................... 14 
Recent Developments ....................................................................................................... 14 
Other Agency-Specific Mentor-Protégé Programs ........................................................................ 15 
DHS Mentor-Protégé Program ................................................................................................ 16 
Regulations Governing the DHS Mentor-Protégé Program .............................................. 16 
Participant Benefits ........................................................................................................... 17 
Recent Developments ....................................................................................................... 17 
DOT Funding Recipients’ Mentor-Protégé Programs ............................................................. 19 
Regulations Governing DOT Mentor-Protégé Programs .................................................. 20 
Participant Benefits ........................................................................................................... 21 
Concluding Observations .............................................................................................................. 21 
 
Tables 
Table 1. Other Agencies with Agency-Specific Mentor-Protégé Programs .................................. 17 
 
Table A-1. Tabular Comparison of Selected Agencies’ Mentor-Protégé Programs ....................... 23 
  
Appendixes 
Appendix. Comparison of Selected Agencies’ Mentor-Protégé Programs .................................... 23 
 
Contacts 
Author Information ........................................................................................................................ 24 
 

Small Business Mentor-Protégé Programs

Congressional Research Service 1

Introduction

Mentor-protégé programs are designed to assist small business development, focusing on

enhancing the protégé’s capacity to serve as either a prime contractor or a subcontractor in federal

contracts. These programs typically seek to pair new businesses and more experienced businesses

in mutually beneficial relationships. Protégés may receive financial, technical, or management

assistance from mentors in obtaining and performing federal contracts or subcontracts, or serving

as suppliers under such contracts or subcontracts, whereas mentors may receive credit toward

subcontracting goals, reimbursement of certain expenses,

or other incentives for assisting

protégés.

Five federal agencies have SBA-approved mentor-protégé programs:

 Department of Energy,

 Department of Homeland Security (DHS),

 National Aeronautics and Space Administration,

 U.S. Small Business Administration (SBA), and

 Department of Transportation.

Two federal agencies have mentor-protégé programs that do not require SBA’s approval because

their programs are not covered by the Small Business Act:

 Department of Defense (DOD) and

 Federal Aviation Administration.

Mentor-protégé programs seek to assist small businesses in various ways.

For example,

 the SBA’s Mentor-Protégé Program is a government-wide mentor-protégé

program for all small business concerns that provides benefits to both mentors

Three federal departments and agencies provide mentors reimbursement for certain expenses related to providing

assistance to protégés: the Department of Defense (DOD), Department of Energy, and Federal Aviation

Administration.

U.S. Small Business Administration (SBA), “Report to Congress on Mentor-Protégé Programs for Fiscal Year 2019,”

August 11, 2020, at https://www.sba.gov/sites/default/files/2021-01/

Final%20FY19%20MPP%20Report%20to%20Congress%20with%20Agency%20Reports-508.pdf.

There were 13 active Mentor-Protégé programs during FY2017. The Departments of Health and Human Services and

Treasury, and the U.S. Agency for International Development ended their mentor-protégé programs during FY2017.

The 10 active mentor-protégé programs at the end of FY2017 were at the Departments of Defense, Energy, Homeland

Security, and Transportation, the Environmental Protection Agency, General Services Administration, National

Aeronautics and Space Administration, and Small Business Administration (three programs—8(a), All Small, and

FAST). The Environmental Protection Agency retired its program on September 19, 2018, and the General Services

Administration retired its program on April 3, 2019. SBA, “Report to Congress on Mentor-Protégé Programs for Fiscal

Year 2017,” June 2019, at http://www.sba.gov/sites/default/files/resources_articles/Final_FY_17_Mentor-

Protege_Report_to_Congress_6-14-2019.pdf; Environmental Protection Agency, “Acquisition Regulation: Removal of

EPA Mentor Protégé Program,” 83 Federal Register 28772-28774, June 21, 2018; and General Services

Administration, “General Services Administration Acquisition Regulation (GSAR); Transition to SBA Mentor-

Protégé,” 84 Federal Register 1410-1411, February 4, 2019.

For purposes of federal procurement law, a business is “small” if it is independently owned and operated; is not

dominant in its field of operations; and meets any definitions or standards established by the SBA. 15 U.S.C.

§632(a)(1)-(2)(A). These standards focus primarily upon the size of the business as measured by the number of

employees or its gross income, but they also take into account the size of other businesses within the same industry.

13 C.F.R. §§121.101-121.108.

Small Business Mentor-Protégé Programs

Congressional Research Service 2

and protégés. For example, mentors can form joint ventures with protégés which

are eligible for small business contracting preferences. Protégés can receive

financial assistance from their mentor in the form of equity investments, loans,

and bonding and guidance on internal business management issues, the federal

procurement process, strategic planning, and general and administrative

assistance, including human resource sharing or security clearance support;

 the DOD Mentor-Protégé Program provides incentives to mentors to assist

various types of small businesses and other entities in performing as

subcontractors or suppliers on DOD contracts. Protégés benefit by gaining access

to DOD contracts and the business development guidance provided by their

mentor;

and

 other agency-specific mentor-protégé programs, such as that of the DHS, provide

mentor firms incentives to subcontract agency prime contracts with small

businesses.

Congressional interest in small business mentor-protégé programs has increased in recent years,

primarily because these programs are designed to help small businesses become competitive

federal contractors, which, in turn, helps small businesses create and retain jobs.

During the 111

Congress, P.L. 111-240, the Small Business Jobs Act of 2010, authorized the

SBA to establish mentor-protégé programs for small businesses owned and controlled by service-

disabled veterans, small businesses owned and controlled by women, and small businesses

located in a HUBZone “modeled” on the now-retired 8(a) Mentor-Protégé Program.

That

program had been operational since July 30, 1998, and was limited to participants in the SBA’s

8(a) Business Development program.

P.L. 111-240 also required the Government Accountability

Office (GAO) to assess the effectiveness of mentor-protégé programs generally.

GAO’s findings

were reported on June 15, 2011.

During the 112

Congress, P.L. 112-239, the National Defense Authorization Act for Fiscal Year

2013, authorized the SBA to establish a mentor-protégé program for “all” small businesses that is

generally “identical” to the 8(a) Mentor-Protégé Program. In an effort to promote uniformity, the

SBA, “SBA Mentor-Protégé Program,” at https://www.sba.gov/federal-contracting/contracting-assistance-programs/

sba-mentor-protege-program#section-header-2.

DOD, “Mentor-Protégé Program (MPP),” at https://business.defense.gov/Programs/Mentor-Protege-Program/.

Department of Homeland Security, “Mentor-Protégé Program,” at https://www.dhs.gov/mentor-protege-program.

SBA, “Small Business Jobs Act: Small Business Mentor-Protégé Programs,” 75 Federal Register 79869, December

20, 2010; SBA, “Semiannual Regulatory Agenda, Small Business Jobs Act: Small Business Mentor-Protégé

Programs,” 76 Federal Register 40140, July 7, 2011; SBA, “Small Business Jobs Act: Small Business Mentor-Protégé

Programs,” 78 Federal Register 1492, January 8, 2013; SBA, “Small Business Mentor-Protégé Programs,” 78 Federal

January 7, 2014.

For additional information and analysis of the SBA’s 8(a) Business Development Program, see CRS Report R44844,

SBA’s “8(a) Program”: Overview, History, and Current Issues, by Robert Jay Dilger.

SBA, “Small Business Size Regulations; 8(a) Business Development/Small Disadvantaged Business Status

Determinations; Rules of Procedure Governing Cases Before the Office of Hearings and Appeals: Final Rule,” 63

Federal Register 35739, June 30, 1998.

Small Business Jobs Act of 2010, P.L. 111-240, §§1345 & 1347, 124 Stat. 2546-47 (September 27, 2010).

Government Accountability Office (GAO), Mentor-Protégé Programs Have Policies That Aim to Benefit

Participants But Do Not Require Postagreement Tracking, GAO-11-548R, June 15, 2011, p. 1, at http://www.gao.gov/

new.items/d11548r.pdf. The statute required that the report be submitted by March 26, 2011—180 days after the act’s

date of enactment, which was September 27, 2010. P.L. 111-240, §1345(c), 124 Stat. 2546.

Small Business Mentor-Protégé Programs

Congressional Research Service 3

act, with some exceptions, prohibits agencies from carrying out mentor-protégé programs that

have not been approved by the SBA.

Based on the authority provided by these two laws, the SBA published a proposed rule in the

Federal Register on February 5, 2015, “to establish a government-wide mentor-protégé program

for all small business concerns, consistent with SBA’s mentor-protégé program for participants in

the SBA’s 8(a) Business Development program in order to make the mentor-protégé rules for

each of the programs as consistent as possible.”

The SBA decided not to implement additional

mentor-protégé programs for service-disabled veteran-owned and -controlled small businesses,

women-owned and -controlled small businesses, and HUBZone small businesses because they

“would be necessarily included within any mentor-protégé program targeting all small business

concerns.”

The SBA also determined that “having five separate small business mentor-protégé

programs could become confusing to the public and procuring agencies and hard to implement by

the SBA.”

The SBA estimated that approximately 2,000 small businesses could become active

in the proposed mentor-protégé program for small businesses.

On July 25, 2016, the SBA published a final rule in the Federal Register establishing, effective

August 24, 2016, the new, government-wide mentor-protégé program for all small businesses.

The final rule also modified the SBA’s 8(a) Mentor-Protégé Program in an effort to make the two

programs as consistent as possible.

As a result, 8(a) small businesses were allowed to participate

in either program. The SBA began to accept applications for the All Small Mentor-Protégé

Program on October 1, 2016.

The SBA noted in the final rule that because its new small business mentor-protégé program will

apply to all federal small business contracts and federal agencies, “conceivably other agency-

specific mentor-protégé programs would not be needed.”

In recognition that one or more

agency-specific mentor-protégé programs may be discontinued and that several of these programs

provide incentives in the contract evaluation process to mentor firms that provide significant

subcontracting work to their protégés, the SBA allows procuring agencies, in appropriate

The Senate version of the bill (S. 3254) did not include these provisions, but the conference report to H.R. 4310,

which was agreed to by the House on December 20, 2012, and by the Senate on December 21, 2012, included them.

The program under P.L. 112-239 need not be identical to the 8(a) Mentor-Protégé Program insofar as differences may

be “necessary” given the types of small businesses included in the program as protégés.

SBA, “Small Business Mentor Protégé Program; Small Business Size Regulations; Government Contracting

Programs; 8(a) Business Development/Small Disadvantaged Business Status Determinations; HUBZone Program;

Women-Owned Small Business Federal Contract Program; Rules of Procedure Governing Cases Before the Office of

Hearings and Appeals,” 80 Federal Register 6618, February 5, 2015.

SBA, “Small Business Mentor Protégé Program; Small Business Size Regulations; Government Contracting

Programs; 8(a) Business Development/Small Disadvantaged Business Status Determinations; HUBZone Program;

Women-Owned Small Business Federal Contract Program; Rules of Procedure Governing Cases Before the Office of

Hearings and Appeals,” pp. 6618-6619.

SBA, “Small Business Mentor Protégé Program; Small Business Size Regulations; Government Contracting

Programs; 8(a) Business Development/Small Disadvantaged Business Status Determinations; HUBZone Program;

Women-Owned Small Business Federal Contract Program; Rules of Procedure Governing Cases Before the Office of

Hearings and Appeals,” p. 6619.

SBA, “Small Business Mentor Protégé Program; Small Business Size Regulations; Government Contracting

Programs; 8(a) Business Development/Small Disadvantaged Business Status Determinations; HUBZone Program;

Women-Owned Small Business Federal Contract Program; Rules of Procedure Governing Cases Before the Office of

Hearings and Appeals,” p. 6628; and SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48574,

July 25, 2016.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48558-48595, July 25, 2016.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48565, July 25, 2016.

Small Business Mentor-Protégé Programs

Congressional Research Service 4

circumstances, to provide subcontracting incentives to mentor firms participating in its mentor-

protégé programs as well.

Since 2016, several federal agencies have ended their mentor-protégé programs and encouraged

interested parties to consider the SBA’s program. In addition, the SBA merged the 8(a) Mentor-

Protégé Program and the All Small Mentor-Protégé Program in an effort to “eliminate confusion

regarding perceived differences between the two Programs, remove unnecessary duplication of

functions within SBA, and establish one, unified staff to better coordinate and process mentor-

protégé applications.”

The merger was effective on November 16, 2020, and the merged

program was retitled as the SBA Mentor-Protégé Program.

This report provides an overview of the federal government’s various small business mentor-

protégé programs. As is discussed below, all of these programs are intended to assist small

businesses in performing as contractors, subcontractors, or suppliers on federal or federally

funded contracts, but the programs differ in their scope and operations. Table A-1 in the

Appendix provides an overview of key differences among the programs.

Mentor-Protégé Programs Administered by the SBA

The SBA administers two mentor-protégé programs, one for firms in its Small Business

Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs

and

one for all small businesses.

Mentoring Networks Under the Federal and State Technology

Partnership Program

In 2000, Congress amended the Small Business Act by directing the SBA Administrator to

establish the Federal and State Technology (FAST) Partnership Program in order to “strengthen

the technological competitiveness of small business concerns in the States”

by providing a wide

range of assistance, including mentoring. Congress further authorized SBA to make grants and

enter cooperative agreements with states and state-endorsed nonprofit organizations as part of the

FAST program so as to enhance

outreach, financial support, and technical assistance to technology-based small business

concerns participating in or interested in participating in an SBIR program, including

initiatives … to establish or operate a Mentoring Network within the FAST program to

provide business advice and counseling that will assist small business concerns that have

been identified by FAST program participants, program managers of participating SBIR

agencies, the [SBA], or other entities that are knowledgeable about the SBIR and STTR

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48566, July 25, 2016.

SBA, “Consolidation of Mentor Protégé Programs and Other Government Contracting Amendments,” 84 Federal

Contracting Amendments,” 85 Federal Register 66146-66199, October 16, 2020.

For additional information and analysis concerning the Small Business Innovation Research (SBIR) and Small

Business Technology Transfer (STTR) programs, see CRS Report R43695, Small Business Research Programs: SBIR

and STTR, by Marcy E. Gallo.

Consolidated Appropriations Act, 2001, P.L. 106-554, §111, 114 Stat. 2764A-674 to 2764A-680 (December 21,

2000) (codified at 15 U.S.C. §657d(b)). The program expired on September 30, 2005, and was reauthorized under the

Consolidated Appropriations Act, 2010, P.L. 111-117, “Small Business Administration”—“Salaries and Expenses,”

123 Stat. 3198 (December 16, 2009) (codified at 15 U.S.C. §657d(b)).

Small Business Mentor-Protégé Programs

Congressional Research Service 5

program as good candidates for the SBIR and STTR programs, and that would benefit from

mentoring.

Such mentoring networks are to (1) provide business advice and counseling; (2) identify

volunteer mentors to guide small businesses in proposal writing, marketing, etc.; (3) have

experience working with small businesses participating in the SBIR and STTR programs; and (4)

agree to reimburse volunteer mentors for out-of-pocket expenses related to service as a mentor.

In FY2021, the SBA awarded 33 FAST partnership awards of up to $125,000 each to state and

local economic development entities, small business technology development centers, women’s

business centers, procurement technical assistance centers, incubators, accelerators, colleges, and

universities.

The program received an appropriation of $2 million each year from FY2010 to

FY2015, $3 million each year from FY2016 to FY2020, $4 million in FY2021, and $6 million in

FY2022.

Recent Developments

During the 114

Congress, P.L. 114-88, the Recovery Improvements for Small Entities After

Disaster Act of 2015 (RISE After Disaster Act), directed the SBA Administrator to provide

special consideration to a FAST applicant that is located in an area affected by a catastrophic

incident.

SBA’s Mentor-Protégé Program

As mentioned, the SBA’s Mentor-Protégé Program, which is administrated by the SBA’s Office

of Business Development, became operational on November 16, 2020, following the merger of

the SBA’s All Small Mentor-Protégé Program and 8(a) Mentor-Protégé Program. As of June 1,

2022, there were 1,565 active SBA Mentor-Protégé Program participants.

SBA regulations govern various aspects of the Mentor-Protégé Program, including who may

qualify as a mentor or protégé, the content of written agreements between mentors and protégés,

and the SBA’s evaluation of the mentor-protégé relationship.

15 U.S.C. §657d(c)(1)(E)(ii).

15 U.S.C. §657e(c)(1)-(5).

SBA, “SBA Awards Grants to 33 Organizations to Help Underserved Communities Succeed with the Small Business

Innovation Research Program,” August 11, 2021, at https://www.sba.gov/article/2021/aug/11/sba-awards-grants-33-

organizations-help-underserved-communities-succeed-small-business-

innovation?utm_medium=email&utm_source=govdelivery.

P.L. 111-117; P.L. 112-8; P.L. 112-74; P.L. 112-175; P.L. 113-76; P.L. 113-235; P.L. 114-113; P.L. 115-31; P.L.

115-141; P.L. 116-6; P.L. 116-93; P.L. 116-260; Mrs. Nita Lowey, “Explanatory Statement Submitted by Mrs. Lowey,

Chairwoman of the House Committee on Appropriations, Regarding the House Amendment to the Senate Amendment

to H.R. 133, Consolidated Appropriations Act, 2021,” House debate, Congressional Record, vol. 166, part No. 218—

Book IV (December 21, 2020), p. H8443; and U.S. House of Representatives, Committee on Appropriations, “House

Report: Division E—Financial Services and General Government Appropriations Act, 2022,” at

https://docs.house.gov/billsthisweek/20220307/BILLS-117RCP35-JES-DIVISION-F.pdf.

SBA, “Active Mentor-Protégé Agreements,” at https://www.sba.gov/document/support-active-mentor-protege-

agreements.

Small Business Mentor-Protégé Programs

Congressional Research Service 6

Mentor Requirements

Mentors must

1. be organized for profit or as an agricultural cooperative;

2. demonstrate a commitment and the ability to assist small businesses;

3. be approved by the SBA;

4. demonstrate that it “is capable of carrying out its responsibilities to assist the

protégé firm under the proposed mentor-protégé agreement”;

5. possess “good character”;

6. not be debarred or suspended from government contracting;

and

7. be able to “impart value to a protégé firm due to lessons learned and practical

experienced gained through its knowledge of general business operations and

government contracting.”

Generally, a mentor will have no more than one protégé at a time, but the SBA may authorize

mentors to have more than one protégé at a time “where it can demonstrate that additional

mentor-protégé relationship will not adversely affect the development of either protégé firm.”

Mentors cannot, under any circumstances, have more than three protégés at a time.

Protégé Requirements

Protégés must

1. be organized for profit or as an agricultural cooperative;

2. “qualify as small for the size standard corresponding to its primary NAICS code

or identify that it is seeking business development assistance with respect to a

secondary NAICS code and qualify as small for ... that NAICS code”;

and

3. have a proposed mentor prior to applying for the program.

Protégés are generally expected to have no more than one mentor at a time. However, under

specified conditions, the SBA may approve a second mentor for the protégé.

SBA, “SBA Mentor-Protégé Program,” at https://www.sba.gov/federal-contracting/contracting-assistance-programs/

sba-mentor-protege-program#section-header-2.

13 C.F.R. §125.9(b). Previously, nonprofit entities were eligible to serve as mentors. For discussion concerning

restricting eligibility to for profit entities, see SBA, “Small Business Mentor Protégé Program,” 81 Federal Register

48562, 48563, July 25, 2016.

13 C.F.R. §125.9(a).

13 C.F.R. §125.9(b)(1)(i).

13 C.F.R. §125.9(b)(1)(ii).

13 C.F.R. §125.9(b)(1)(iii).

13 C.F.R. §125.9(b)(1)(iv).

13 C.F.R. §125.9(b)(4).

SBA, “SBA Mentor-Protégé Program,” at https://www.sba.gov/federal-contracting/contracting-assistance-programs/

sba-mentor-protege-program#section-header-2.

13 C.F.R. §125.9(c)(1). Protégés may self-certify its status as a small business. See 13 C.F.R. §125.9(c)(1)(i).

SBA, “SBA Mentor-Protégé Program,” at https://www.sba.gov/federal-contracting/contracting-assistance-programs/

sba-mentor-protege-program#section-header-2; and 13 C.F.R. §125.9(e)(2)(i).

13 C.F.R. §125.9(c)(2). The specified circumstances are that the “second relationship will not compete or otherwise

Small Business Mentor-Protégé Programs

Congressional Research Service 7

Written Agreements

The SBA requires mentors and protégés to enter a written agreement, approved by the SBA’s

Associate Administrator for Business Development or designee, which sets forth the protégé’s

needs and describes the assistance the mentor will provide.

This agreement generally obligates

the mentor to furnish assistance to the protégé for at least one year,

although it does allow either

mentor or protégé to terminate the agreement with 30 days’ advance notice to the other party and

the SBA.

In addition, the agreement provides that the SBA will review the mentor-protégé

agreement annually to determine whether to approve its continuation.

The agreement may not

exceed three years, but may be extended for a second three years.

Any changes made to the

agreement must be approved by the SBA. Also, an SBA determination of affiliation or control

must not exist between the mentor and the protégé based solely on the mentor-protégé agreement

or any assistance provided pursuant to the agreement.

The SBA’s annual evaluation is based, in part, on the protégé’s annual reports regarding its

contacts with its mentor and the benefits it has received from the mentor-protégé relationship,

including (1) all technical or management assistance the mentor has provided to the protégé; (2)

all loans to or equity investments made by the mentor in the protégé; (3) all subcontracts awarded

to the protégé by the mentor; (4) all federal contracts awarded to a joint venture of the mentor and

protégé; and (5) a narrative describing the success the assistance had had in meeting the protégé’s

developmental needs and any problems encountered.

The SBA may terminate the mentor-protégé agreement at any time if it determines that the

protégé is not adequately benefiting from the relationship or that the parties are not complying

with any of the agreement’s terms or conditions.

Participant Benefits

Participation in the SBA Mentor-Protégé Program is intended to benefit both mentors and

protégés. For example, mentors may form joint ventures with their protégés who are eligible for

contracts set aside for small businesses, provided that the protégé qualifies as small for the

contract.

Mentor firms and joint ventures involving mentor firms would otherwise generally be

ineligible for such contracts because they would not qualify as “small” under the SBA

conflict with the assistance set forth in the first mentor-protégé relationship and (i) the second relationship pertains to a

secondary NAICS code; or (2) the protégé firm is seeking to acquire a specific expertise that the first mentor does not

possess.” Also, “the SBA may authorize a participant to be both a protégé and a mentor at the same time where the

participant can demonstrate that the second relationship will not compete or otherwise conflict with the first mentor-

protégé relationship.” See 13 C.F.R. §125.9(c)(3).

13 C.F.R. §125.9(e)(1).

13 C.F.R. §125.9(e)(1)(iii).

13 C.F.R. §125.9(e)(4).

13 C.F.R. §125.9(e)(5).

13 C.F.R. §125.9(d)(5).

13 C.F.R. §125.9(g)(1)(i)-(v).

13 C.F.R. §125.9(e)(8).

13 C.F.R. §125.9(d)(1).

Small Business Mentor-Protégé Programs

Congressional Research Service 8

regulations. Mentor firms may also acquire an equity interest of up to 40% in the protégé firm in

order to help the protégé firm raise capital.

As mentioned, in addition to receiving financial assistance from their mentors, protégés may also

receive guidance on internal business management issues, the federal procurement process,

strategic planning, and general and administrative assistance, including human resource sharing

or security clearance support.

Protégés not only receive various forms of assistance from their mentors, but also may generally

retain their status as “small businesses” while doing so.

If they received similar assistance from

entities other than their mentors, they could risk being found to be other than “small” because of

how the SBA determines size. The SBA combines the gross income of the firm, or the number of

its employees, with those of its “affiliates” when determining whether the firm is small,

and the

SBA could potentially find that firms are affiliates because of assistance such as that which

mentors provide to protégés.

However, SBA regulations provide that “[n]o determination of

affiliation or control may be found between a protégé firm and its mentor based on the mentor-

protégé agreement or any assistance provided pursuant to the agreement.”

GAO’s Reports and Legislative Action

As mentioned, during the 111

Congress, P.L. 111-240, the Small Business Jobs Act of 2010,

required GAO to study federal mentor-protégé programs “to determine whether the programs and

relationships are effectively supporting the goal of increasing the participation of small business

concerns in government contracting.”

GAO’s report was submitted to the House and Senate

Committees on Small Business on June 15, 2011.

In this report, GAO examined mentor-protégé programs in 13 federal agencies it identified as

having a mentor-protégé program, including the SBA. It reported that most federal mentor-

protégé programs had “similar policies and procedures,” but that some differences exist.

For

example, GAO noted that “different agencies have varying guidance regarding the length of

mentor-protégé agreements and whether protégés are allowed to have more than one mentor,” and

the “DOD mentor-protégé program is the only mentor-protégé program mandated by law and

receiving appropriated funding.”

GAO also reported that “most agencies have policies and

13 C.F.R. §125.9(d)(2).

SBA, “SBA Mentor-Protégé Program,” at https://www.sba.gov/federal-contracting/contracting-assistance-programs/

sba-mentor-protege-program#section-header-2.

13 C.F.R. §125.9(d)(3). But see 13 C.F.R. §121.103(b)(6) (noting that, while a protégé is not an affiliate of its mentor

because it receives assistance from its mentor under the mentor-protégé program, “[a]ffiliation may be found … for

other reasons”).

13 C.F.R. §§121.101-121.108. Firms are “affiliates” when “one controls or has the power to control the other, or a

third party or parties controls or has the power to control both.” See 13 C.F.R. §121.103(a)(1).

See generally 13 C.F.R. §121.103.

13 C.F.R. §125.9(d)(4).

P.L. 111-240, §1345(a), 124 Stat. 2546.

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, GAO-11-548R, June 15, 2011, p. 1, at http://www.gao.gov/new.items/d11548r.pdf.

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, p. 4.

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, pp. 4-5.

Small Business Mentor-Protégé Programs

Congressional Research Service 9

reporting requirements to help ensure that protégés are benefiting from participation in their

mentor-protégé programs.”

However, it found that only DOD, the National Aeronautics and

Space Administration, and the U.S. Agency for International Development “have policies in place

to collect information on protégé progress after the mentor-protégé agreements have

terminated.”

GAO recommended that all of the agencies it examined “consider collecting and

maintaining protégé post-completion information” because that information “could be used to

help [the agencies] further assess the success of their programs and help ensure that small

businesses are benefiting from participation in the programs as intended.”

During the 112

Congress, P.L. 112-239, the National Defense Authorization Act for Fiscal Year

2013, sought to reduce the variation that GAO found among agency-specific mentor-protégé

programs by requiring that any such programs be approved by the SBA pursuant to regulations,

“which shall ensure that such programs improve the ability of protégés to compete for Federal

prime contracts and subcontracts.”

The SBA administrator was required to issue regulations

with respect to mentor-protégé programs not later than 270 days after the bill’s enactment, which

was January 2, 2013 (the regulations were issued on July 25, 2016). At a minimum, these

regulations must address 10 criteria, including (1) eligibility for program participants, (2) the

types of developmental assistance provided to protégés, (3) the length of mentor-protégé

relationships, (4) the benefits that may accrue to the mentor as a result of program participation,

and (5) the reporting requirements during and following program participation.

DOD’s Mentor-

Protégé Program and mentoring assistance under the Small Business Innovation Research

Program and the Small Business Technology Transfer Program are exempt from the approval

process.

Effective August 24, 2016, federal agencies (other than DOD and the two exempt programs) were

provided a year to submit a plan to the SBA Administrator for approval to continue a previously

existing mentor-protégé program. Approval is contingent on whether the proposed program will

assist protégés to compete for federal prime contracts and subcontracts and whether it complies

with the rules and regulations of the SBA’s mentor-protégé programs (as set forth in 13 C.F.R.

§§125.9).

As mentioned, five federal agencies currently have SBA-approved mentor-protégé programs

(Department of Energy, Department of Homeland Security, Department of Transportation,

National Aeronautics and Space Administration, and the SBA) and two federal agencies have

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, p. 9.

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, p. 9.

GAO, Mentor-Protégé Programs Have Policies That Aim to Benefit Participants But Do Not Require Postagreement

Tracking, p. 9.

Any federal mentor-protégé program in effect at the date of the bill’s enactment must submit plans to the SBA for

approval within 6 months of the SBA’s promulgation of rules with respect to mentor-protégé programs and receive

final approval or denial within 180 days after receipt. In addition, DOD’s Mentor-Protégé Program and mentoring

assistance under the Small Business Innovation Research Program and the Small Business Technology Transfer

Program were made exempt from the approval process.

These provisions originated with H.R. 3985, the Building Better Business Partnerships Act of 2012. The Senate

version of the bill (S. 3254) did not include these provisions, but they were included in the bill’s conference report,

which was agreed to by the House on December 20, 2012, and by the Senate on December 21, 2012. The bill was

signed by President Obama on January 2, 2013.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48589, July 25, 2016.

Small Business Mentor-Protégé Programs

Congressional Research Service 10

mentor-protégé programs that do not require SBA’s approval because their programs are not

covered by the Small Business Act (DOD and the Federal Aviation Administration).

In addition, before starting a new mentor-protégé program, agency heads must submit a plan and

receive the SBA Administrator’s approval.

Agencies sponsoring an agency-specific mentor-

protégé program must report annually to the SBA specific information, such as the number and

type of small business participants, the assistance provided, and the protégés’ progress in

competing for federal contracts.

DOD Mentor-Protégé Program

Congress authorized a pilot mentor-protégé program for DOD in 1990. The program’s purposes

are to

(1) enhance the capabilities of disadvantaged small business concerns to perform as

subcontractors and suppliers under Department of Defense contracts and other contracts

and subcontracts; and (2) increase the participation of such business concerns as

subcontractors and suppliers under Department of Defense contracts, other Federal

Government contracts, and commercial contracts.

DOD’s Mentor-Protégé Program began on October 1, 1991, and was the first federal mentor-

protégé program to become operational. Originally scheduled to expire in 1994,

it has been

repeatedly extended, most recently through FY2024 for the formation of new agreements, and

FY2026 for the reimbursement of incurred costs under existing agreements.

SBA approved the Department of Energy, the National Aeronautics and Space Administration (NASA), and the

Department of Homeland Security mentor-protégé programs on February 20, 2018, for five years. See John R. Bashista

and S. Keith Hamilton, P.E., “Class Deviation: Determination and Findings, Department of Energy Acquisition

Regulation (DEAR) Mentor Protégé Participation, DEAR 919.7001-919.7003, DEAR 919.7006-919.7007, and

952.219-70,” at https://www.energy.gov/sites/prod/files/2019/02/f60/PF%202019-15%20Class%20Deviation.pdf;

NASA, Office of Small Business Programs, “NASA Mentor-Protégé Program: Fostering Successful Partnerships the

Possibilities are Endless,” power point presentation, p. 4, at https://osbp.nasa.gov/docs/event-presentations/2018_05/08/

1130_Mentor-Protege-Program_TKalisa.pdf; and Department of Homeland Security, Office of Legislative Affairs,

“Correspondence with the author,” April 1, 2021.

The SBA approved the Department of Transportation (DOT) mentor-protégé program on March 13, 2019, for five

years. DOT, Office of the Secretary of Transportation, Office of Public Affairs, correspondence with the author, March

31, 2021.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48589, July 25, 2016.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48590, July 25, 2016.

P.L. 114-92, the National Defense Authorization Act for Fiscal Year 2016, §861 (codified, as amended, at 10 U.S.C.

§2302 note). See P.L. 101-510, An Act to Authorize Appropriations for Fiscal Year 1991 for Military Activities of the

Department of Defense, for Military Construction, and for Defense Activities of the Department of Energy, to Prescribe

Personnel Strengths for the Armed Forces and for Other Purposes, §831, 104 Stat. 1607-08 (November 5, 1990) for

earlier language. The wording of the program’s purpose was modified somewhat by P.L. 114-92 in an effort to better

reflect the goals of the mentor-protégé programs sponsored by the SBA and other civilian agencies.

P.L. 101-510, An Act to Authorize Appropriations for Fiscal Year 1991 for Military Activities of the Department of

Defense, for Military Construction, and for Defense Activities of the Department of Energy, to Prescribe Personnel

Strengths for the Armed Forces and for Other Purposes, at §831(j)(1), 104 Stat. 1610 (providing that firms eligible to

participate in the program may enter mentor-protégé agreements during the period commencing on October 1, 1991,

and ending on September 30, 1994). Under this provision, firms could incur costs for reimbursement through

September 30, 1996, and could receive credit for unreimbursed costs through September 30, 1999. See also U.S.

General Accounting Office, Defense Contracting: Interim Report on Mentor-Protégé Program for Small

Disadvantaged Firms, GAO/NSIAD-92-135, March 30, 1992, pp. 1-3, at http://www.gao.gov/assets/220/215849.pdf.

See, e.g., P.L. 112-81, the National Defense Authorization Act for FY2012, §867, 125 Stat. 1526; P.L. 114-92, the

Small Business Mentor-Protégé Programs

Congressional Research Service 11

DOD’s Mentor-Protégé Program differs from the SBA’s Mentor-Protégé Program in that its

primary focus is upon small businesses performing subcontracts and as suppliers on federal

contracts, not upon small businesses performing federal contracts. In addition, mentors in the

DOD program may provide assistance to their protégés that is somewhat different than that which

mentors may provide to protégés in the SBA’s Mentor-Protégé Program. Notably, such assistance

may include advance payments, which federal agencies are generally prohibited from making,

and progress (installment) payments, which are generally discouraged under federal procurement

law.

As of January 1, 2018 (the latest available data), there were 63 active mentor-protégé agreements

involving 39 mentors and 63 protégés.

One mentor had seven protégés, 1 mentor had 6

protégés, 1 mentor had 5 protégés, 2 mentors had 3 protégés, 5 mentors had 2 protégés, and 29

mentors had one protégé.

DOD regulations govern various aspects of the DOD Mentor-Protégé Program, including who

may qualify as a mentor or protégé, the content of written agreements between mentors and

protégés, and the DOD’s evaluation of the mentor-protégé relationship.

Mentor Requirements

A mentor must

1. be eligible for the award of federal contracts;

2. demonstrate that it is qualified to provide assistance that contributes to the

program;

3. be of good financial health and character;

4. not be debarred or suspended from government contracting; and

5. be capable of “imparting value to a protégé firm because of experience gained as

a DOD contractor through knowledge of general business operations and

government contracting,” as demonstrated by

a. having received DOD contracts totaling at least $100 million during the

previous fiscal year;

b. being an other-than-small business, unless a waiver to the small business

exception has been obtained from the SBA;

c. being a prime contractor with an active subcontracting plan; or

National Defense Authorization Act for FY2016, §861; and P.L. 116-92, the National Defense Authorization Act for

FY2020, §872.

Advance payments are payments made to a contractor before any costs have been incurred on a contract, while

progress payments are payments made during the performance of work, but before completion of the contract, on the

basis of either a percentage of completion of the work or the incurrence of costs. Advance payments are generally only

authorized when (1) the contractor gives adequate security; (2) the payments do not exceed the contract price; and (3)

the agency head or a designee determines that advance payment is in the public interest or facilitates the national

defense. See, e.g., 48 C.F.R. §32.402(b)-(c). Progress payments made on the basis of percentage of completion under

construction or certain other contracts are considered invoice payments and are permissible. See 48 C.F.R. §32.500(b).

Progress payments made on the basis of performance milestones are considered financing payments and are likewise

permissible. Other progress payments based on costs are generally considered “unusual progress payments” and may be

used only when authorized in “exceptional cases.” See 48 C.F.R. §§32.501, 32.501-2.

DOD, “Active MPP [Mentor-Protégé Program] Agreements,” January 1, 2018.

Small Business Mentor-Protégé Programs

Congressional Research Service 12

d. having graduated from the 8(a) Business Development Program with

documentation of its ability to serve as a mentor.

Mentors and protégés are solely responsible for finding their counterpart.

Mentors can have

several protégés.

Protégé Requirements

A protégé must

1. be a small business;

2. be eligible for the award of federal contracts;

3. qualify as small for the size standard corresponding to its primary NAICS code;

4. be not owned or managed by individuals or entities that directly or indirectly

have stock options or convertible securities in the mentor firm; and

5. be at least one of the following:

a. a qualified HUBZone small business;

b. a women-owned small business;

c. a service-disabled veteran-owned small business;

d. an entity owned and controlled by an Indian tribe or Native Hawaiian

organization;

e. an entity owned and controlled by socially and economically disadvantaged

individuals;

f. a qualified organization employing severely disabled individuals;

g. a nontraditional defense contractor; or

h. an “entity that currently provides goods or services in the private sector that

are critical to enhancing the capabilities of the defense supplier base and

fulfilling key DOD needs.”

Protégés cannot have more than one mentor at a time and may only participate in the program

during the 5-year period beginning on the date the protégé enters into its first mentor-protégé

agreement.

48 C.F.R. Ch. 2, Appendix I, I-102(a)(1)-(3). Initially, only small businesses owned and controlled by socially and

economically disadvantaged individuals could qualify as protégés. See P.L. 101-510, §831(m)(2), 104 Stat. 1611. The

list of eligible protégés was later expanded. See, e.g., An Act to Authorize Appropriations for Fiscal Year 2001 for

Military Activities of the Department of Defense, for Military Construction, and for Defense Activities of the

Department of Energy, to Prescribe Personnel Strengths for Such Fiscal Year for the Armed Forces, and for Other

Purposes, P.L. 106-398, §807, 114 Stat. 1654A-208 (October 30, 2000).

DOD, Office of Small Business Programs, “Mentor-Protégé Program: How to Participate,” at

https://business.defense.gov/Programs/Mentor-Protege-Program/How-to-Participate/.

Socially and economically individuals are defined by section 8(d)(3)(C) of the Small Business Act (15 U.S.C.

§637(D)(3)(C)).

48 C.F.R. Ch. 2, Appendix I, I-102(b). See P.L. 101-510, §831(m)(2), 104 Stat. 1611.

48 C.F.R. Ch. 2, Appendix I, I-104(e).

Small Business Mentor-Protégé Programs

Congressional Research Service 13

Written Agreements

DOD requires mentors and protégés to enter a written agreement, approved by DOD, which sets

forth the mentor and protégé’s program eligibility, describes the assistance the mentor will

provide, and contracting goals.

The agreement generally has a term that does not exceed three

years, but can be extended up to two additional years with DOD approval.

Mentors and protégés

may terminate the agreement with 30 days’ advance notice to the other party and DOD.

There are three types of DOD Mentor-Protégé Program written agreements:

 directly reimbursable agreements, which provide mentors monetary reimbursements only

for the cost of developmental assistance incurred by the mentor and provided to the

protégé according to the approved agreement;

 credit agreements, which allow mentors to receive credit toward subcontracting goals for

developmental costs incurred by the mentor according to the agreement;

and

 hybrid agreements, which provide credits for the first year of the agreement and then can

be modified to include monetary reimbursements in the remaining years.

Mentors must report to DOD on the progress made under their mentor-protégé agreements

semiannually for the periods ending on March 31

and September 30

throughout the

agreement’s term. The September 30

report must address the entire fiscal year.

Protégés must report to DOD on the progress made under their mentor-protégé agreements

annually by October 31

. The report must include data on employment, revenues, and

participation in DOD contracts during each fiscal year of program participation and in each of the

two fiscal years following its participation in the program.

The protégé’s report may be

provided as part of the mentor’s September 30

report.

48 C.F.R. Ch. 2, Appendix I, I-107(a)-(j).

48 C.F.R. Ch. 2, Appendix I, I-107(k).

48 C.F.R. Ch. 2, Appendix I, I-107(l)-(m); and 48 C.F.R. Ch. 2, Appendix I, I-111(a).

48 C.F.R. Ch. 2, Appendix I, I-109. Mentors may not receive more than $1 million in reimbursements per fiscal year

without DOD written approval that unusual circumstances justify a higher amount. See 48 C.F.R. Ch. 2, Appendix I, I-

109(d).

48 C.F.R. Ch. 2, Appendix I, I-110.1(a). All credit agreements are sponsored by the DOD, Defense Contract

Management Agency, Office of Small Business Programs. Other agreements are sponsored by the DOD cognizant

component Director (e.g., Director, Department of the Navy, Office of Small Business Program, etc.). Mentors receive

credit for four times the costs attributable to assistance provided by small business development centers, historically

Black colleges and universities, minority institutions, and procurement technical assistance centers; three times the

amount of such costs attributable to assistance furnished by the mentor’s employees; and two times the amount of other

such costs incurred by the mentor in carrying out the developmental assistance program. See 48 C.F.R. Ch. 2,

Appendix I, I-110.1(d)(1)-(3).

DOD, Department of the Navy, Office of Small Business Program, Small Business Development: Industrial

Solutions for the Warfighter: Mentor-Protégé Guidebook for Industry and Acquisition Professional, June 2020, p. 2, at

https://www.secnav.navy.mil/smallbusiness/Documents/DON%20MPP%20Guidebook%20(June%202020).pdf.

48 C.F.R. Ch. 2, Appendix I, I-112(a). The reports are due 30 days after the close of each reporting period.

48 C.F.R. Ch. 2, Appendix I, I-112(b).

48 C.F.R. Ch. 2, Appendix I, I-112(c).

Small Business Mentor-Protégé Programs

Congressional Research Service 14

Participant Benefits

As mentioned, mentors can receive reimbursement of specified assistance costs and credit for

unreimbursed costs toward applicable subcontracting goals. DOD and the mentor may agree that

DOD will reimburse the mentor for certain advance payments or progress (installment) payments

made to assist protégé firms in performing a subcontract or supplying goods or services under a

contract.

Alternatively, DOD may credit toward the mentor’s subcontracting plan costs incurred

under the credit agreement in the following multiples: four times the costs attributable to

assistance provided by small business development centers, historically Black colleges and

universities, minority institutions, and procurement technical assistance centers; three times the

costs attributable to assistance furnished by the mentor’s employees; and two times the amount of

other such costs (such as travel or training) incurred by the mentor in carrying out the

developmental assistance program.

Protégés benefit from the program by increasing their ability to participate in DOD, federal, and

commercial contracts by teaming with the mentor. Protégés can also receive technical and

business development assistance from their mentor. In addition, as mentioned, if specified in the

subcontract terms and conditions, protégés can receive advance payments and progress

(installment) payments from their mentor prior to the project’s completion.

Recent Developments

As mentioned, P.L. 116-92, the National Defense Authorization Act for FY2020, extended the

DOD Mentor-Protégé Program’s authorization through FY2024 for the formation of new

agreements, and FY2026 for the reimbursement of incurred costs under existing agreements.

The act also increased the size standard for determining eligibility for DOD’s Mentor-Protégé

Program from less than half of the SBA size standard assigned to its corresponding NAICS code

to not more than the SBA’s size standard assigned to its corresponding NAICS code. This change

was designed to better align DOD’s Mentor-Protégé Program’s eligibility requirements with

those of the now-retired SBA 8(a) Mentor-Protégé Program (which increased its size standard for

determining eligibility from less than half to not more than the SBA’s size standard assigned to its

corresponding NAICS code in 2016).

48 C.F.R. §219.7103-2(b) & (f); 48 C.F.R. §252.232-7005. The amount of such payments generally may not exceed

$1 million per year. But see 48 C.F.R. Ch. 2, Appendix I, I-108(a)(6) (permitting developmental costs in excess of $1

million when a specific justification for such costs has been presented). When the mentor will be reimbursed for

developmental assistance provided to the protégé, the mentor must establish the accounting treatment of developmental

assistance costs before incurring such costs. 48 C.F.R. §219.7104(b). Additionally, under DOD regulations, the

subcontract between the mentor and protégé must include provisions substantially the same as the provisions in the

Federal Acquisition Regulation (FAR) regarding advance payments; the contractor must have administered the advance

payments in accordance with FAR Subpart 32.4; and the contractor must agree that any financial loss resulting from the

protégé’s failure or inability to repay any unliquidated advance payments is the sole financial responsibility of the

contractor. 48 C.F.R. §252.232-7005.

48 C.F.R. Ch. 2, Appendix I, I-110.1(d)(1)-(3). Subcontracts awarded to certain current or former protégés also count

toward these goals. See 48 C.F.R. §252.219-7003(c).

48 C.F.R. Ch. 2, Appendix I, I-108(a)(4); and 48 C.F.R. Ch. 2, Appendix I, I-109(a)&(b).

Previously, P.L. 114-92, the National Defense Authorization Act for Fiscal Year 2016, had extended the DOD

Mentor-Protégé Program’s authorization through FY2018 for the formation of new agreements, and FY2021 for the

reimbursement of incurred costs under existing agreements.

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48564, 48565, July 25, 2016

Small Business Mentor-Protégé Programs

Congressional Research Service 15

DOD provided the program $23.2 million in FY2017, $19.6 million in FY2018, $29.8 million in

FY2019, and $31.7 million in FY2020.

DOD announced in its FY2021 congressional budget

justification document that it intended to zero out the Mentor-Protégé Program (i.e., transfer the

funds to other uses) in FY2021, and “shift from a cost reimbursable program to an allowable cost

program to attract and expand participation in the MPP.”

However, P.L. 116-260, the

Consolidated Appropriations Act, 2021, and P.L. 117-103, the Consolidated Appropriations Act,

2022, included a provision that prevented DOD from zeroing out the program by requiring DOD

to use the program’s appropriated funds “solely for the purpose of implementing a Mentor-

Protégé Program developmental assistance agreement pursuant to section 831 of the National

Defense Authorization Act for Fiscal Year 1991.” The program subsequently received $30 million

in FY2021, and is expected to receive $33 million in FY2022.

Other Agency-Specific Mentor-Protégé Programs

Other agencies, like DHS, have established independent mentor-protégé programs to encourage

their large prime contractors to work with small business subcontractors when performing agency

contracts. Because these programs are not based in statute, unlike the SBA and DOD programs

discussed above, they generally rely upon existing authorities (e.g., authorizing use of evaluation

factors) or publicity to incentivize mentor participation. Such programs generally supplement the

SBA’s Mentor-Protégé Program.

DHS’s Mentor-Protégé Program is discussed here as a representative example of such programs.

Several other agencies have similar programs, which are described in Table 1. Note that while

this report describes these programs as they presently exist, certain changes may be made to these

programs in light of the requirements of the National Defense Authorization Act for FY2013 (P.L.

112-239). This legislation generally requires that agency-specific mentor-protégé programs be

approved by the SBA pursuant to regulations that would require such programs to address, among

other things, (1) eligibility for program participants, (2) the types of developmental assistance

provided to protégés, (3) the length of mentor-protégé relationships, (4) the benefits that may

DOD, Office of the Secretary of Defense, “Fiscal Year (FY) 2018 Budget Submission: Defense Wide Justification

Book Volume 1 of 2,” February 2017, Exhibit P-40, Budget Line Item Justification: PB 2017 Office of the Secretary of

Defense, at http://comptroller.defense.gov/Portals/45/Documents/defbudget/FY2018/budget_justification/pdfs/

02_Procurement/OSD_0300D_FY18_PB_FINAL.pdf; DOD, Office of the Secretary of Defense, “Fiscal Year (FY)

2019 Budget Submission: Defense Wide Justification Book Volume 1 of 2,” February 2018, Exhibit P-40, Budget Line

Item Justification: PB 2019 Office of the Secretary of Defense, at http://comptroller.defense.gov/Portals/45/Documents/

defbudget/fy2019/budget_justification/pdfs/02_Procurement/U_PROCUREMENT_MasterJustificationBook_Defense-

Wide_PB_2019.pdf; and DOD, Office of the Secretary of Defense, “Fiscal Year (FY) 2020 Budget Submission:

Defense Wide Justification Book; Procurement: Office of the Secretary of Defense,” March 2019, Exhibit P-40, Budget

Line Item Justification: PB 2020 Office of the Secretary of Defense, at https://comptroller.defense.gov/Portals/45/

Documents/defbudget/fy2020/budget_justification/pdfs/02_Procurement/13_0300_OSD_PB2020.pdf.

DOD, Office of the Secretary of Defense, “Department of Defense Fiscal Year (FY) 2021 Budget Estimates: Defense

Wide Justification Book Volume 1 of 2,” February 2020, Exhibit P-40, Budget Line Item Justification: PB 2021 Office

of the Secretary of Defense, at https://comptroller.defense.gov/Portals/45/Documents/defbudget/fy2021/

budget_justification/pdfs/02_Procurement/PROC_Vol1_DW_PROC_PB21_Justification_Book_Final.pdf.

DOD, Office of the Secretary of Defense, “Department of Defense Fiscal Year (FY) 2023 Budget Estimates:

Defense-Wide Justification Book Volume 1 of 1,” April 2022, Procurement, Defense-Wide, Exhibit P-5, Cost

Analysis: PB 2023 Office of the Secretary of Defense, at

https://comptroller.defense.gov/Portals/45/Documents/defbudget/fy2023/budget_justification/pdfs/02_Procurement/PR

OC_MJB_DW_Vol1_PB_2023.pdf.

Small Business Mentor-Protégé Programs

Congressional Research Service 16

accrue to the mentor as a result of program participation, and (5) the reporting requirements

during and following program participation.

DHS Mentor-Protégé Program

DHS established its mentor-protégé program in 2003 to “motivate and encourage large business

prime contractor firms to provide mutually beneficial developmental assistance” to small

businesses.

Mentor firms may provide various types of assistance to their protégés, including

temporary assignment of personnel to the protégé firm for the purpose of training, rent-free use of

facilities or equipment, overall business management/planning, financial and organizational

management, business development, technical assistance, property, loans, and other types of

assistance.

As of September 15, 2020, DHS had 39 active mentor-protégé agreements involving 32 mentors

and 39 protégés.

Seven mentors each had 2 protégés, and 25 mentors each had 1 protégé.

The

DHS program does not receive a separate funding appropriation.

Regulations Governing the DHS Mentor-Protégé Program

Mentors are “large prime contractors capable of providing developmental assistance.”

Protégé

firms can be small businesses, veteran-owned small businesses, service-disabled veteran-owned

small businesses, HUBZone small businesses, “small disadvantaged businesses,”

100

and women-

owned small businesses.

101

Although mentors and protégés apparently do not need to be approved

by DHS, they are required, by regulation, to have their mentor-protégé agreement approved by

the DHS Office of Small and Disadvantaged Business Utilization (OSDBU).

102

This mentor-

protégé agreement is evaluated on the extent to which the mentor plans to provide developmental

assistance. If accepted into the program, the mentor-protégé relationship generally lasts for 36

months. The mentor and protégé are required to submit a jointly written mid-term progress report

at 18 months, and, at the end of the 36 months, the mentor and protégé are required to submit a

final report and complete a “lessons learned” evaluation separately. Protégés are also required to

submit a post-award report annually for two years.

103

DHS, “Mentor-Protégé Program,” at https://www.dhs.gov/mentor-protege-program; and DHS, “Department of

Homeland Security Acquisition Regulation,” 68 Federal Register 67868-67870, December 4, 2003.

DHS, “Mentor-Protégé Program,” at https://www.dhs.gov/mentor-protege-program.

DHS, “Mentor-Protégé Companies,” at https://www.dhs.gov/mentor-protege-companies (hereinafter DHS, “Mentor-

Protégé Companies”).

DHS, “Mentor-Protégé Companies.”

48 C.F.R. §3052.219-71(b)(1).

100

“Small disadvantaged businesses” (SDBs) are those owned and controlled by socially and economically

disadvantaged individuals. All SBA 8(a) Business Development Program participating firms are SDBs. However, firms

that are not participating in the 8(a) program may, depending upon the program, also be certified or self-certify as

SDBs.

101

48 C.F.R. §3052.219-71(b)(2).

102

48 C.F.R. §3052.219-71(b)(3).

103

DHS, “Mentor-Protégé Program Details,” at http://www.dhs.gov/xlibrary/assets/opnbiz/osdbu-mentor-protege-

details.pdf.

Small Business Mentor-Protégé Programs

Congressional Research Service 17

Participant Benefits

Participation as a mentor in the DHS Mentor-Protégé Program may serve as a source selection

factor or subfactor in certain negotiated procurements,

104

potentially giving mentor firms an

advantage over nonmentors and, thereby, encouraging firms to become mentors. In addition,

mentors may credit costs incurred in providing assistance to their protégés toward their goals for

subcontracting with small businesses.

105

Mentors are also eligible for an annual award presented

by DHS to the firm providing the most effective developmental support to a protégé.

106

Recent Developments

During the 116

Congress, H.R. 4727, the Department of Homeland Security Mentor-Protégé

Program Act of 2019, was passed by the House by voice vote on December 9, 2019. The bill

would have, among other provisions, provided statutory authorization for DHS’ Mentor-Protégé

Program, allow historically black colleges and universities and minority institutions of higher

education to participate in the program, and establish an annual reporting requirement concerning

the program’s activities and outcomes to the House Committees on Homeland Security and Small

Business.

107

The bill was reintroduced during the 117

Congress on January 1, 2021 (H.R. 408, the

Department of Homeland Security Mentor-Protégé Program Act of 2021) and referred to the

House Committee on Homeland Security. The bill’s text was included in the House-passed

version of the National Defense Authorization Act for FY2002 (H.R. 4350), but was not included

in the bill’s final version that became law (P.L. 117-81).

Table 1. Other Agencies with Agency-Specific Mentor-Protégé Programs

Agency

Eligible Protégés

Incentives for Mentors

Department of Energy

48 C.F.R. Subpart

919.70

(active, SBA approved)

8(a) firms and other small disadvantaged

businesses; historically black colleges and

universities and other minority

institutions of higher learning; women-

owned small businesses; service-disabled

veteran-owned small businesses

Eligibility for award fees based on their

performance as mentors

Subcontracts awarded to protégés count

toward subcontracting goals

Department of Health

and Human Services

48 C.F.R. §352.219-70

(not active)

Small businesses; veteran-owned small

businesses; service-disabled veteran-

owned small businesses; small

disadvantaged businesses; Historically

Underutilized Business Zone (HUBZone)

small businesses; woman-owned small

businesses

Certain assistance provided to protégés

credited toward subcontracting plans

104

48 C.F.R. §3052.219-72.

105

48 C.F.R. §3052.219-71(d). (“For example, a mentor/large business prime contractor would report a $10,000

subcontract to the protégé/small business subcontractor and $5,000 of developmental assistance to the protégé/small

business subcontractor as $15,000.”)

106

DHS, “Mentor-Protégé Program Details,” at https://www.dhs.gov/sites/default/files/publications/Mentor-

Prot%C3%A9g%C3%A9%20Program%20Details_0.pdf.

107

A companion bill, S. 4251, the Department of Homeland Security Mentor-Protégé Program Act of 2020, was

introduced in the Senate on July 21, 2020.

Small Business Mentor-Protégé Programs

Congressional Research Service 18

Agency

Eligible Protégés

Incentives for Mentors

Department of State

48 C.F.R. §619.202-70

(not active)

Small businesses; small disadvantaged

businesses; women-owned small

businesses; HUBZone small businesses;

veteran-owned small businesses; service-

disabled veteran-owned small businesses

Mentor-protégé agreement may be

considered in evaluating adequacy of

proposed subcontracting plan and in

responsibility determinations

Agency mentoring award (nonmonetary)

Department of the

Treasury

48 C.F.R. Subpart

1019.202-70

(not active)

Small businesses; women-owned small

businesses; 8(a) firms and other small

disadvantaged businesses; veteran-owned

small businesses; service-disabled

veteran-owned small businesses;

HUBZone small businesses

Bonus (not to exceed 5% of the relative

importance assigned to technical/

management factors) credited to mentor in

negotiated procurements

Mentor-protégé agreement may be

considered in evaluating adequacy of

proposed subcontracting plan and in

responsibility determinations

Agency mentoring award (nonmonetary)

Department of

Veterans Affairs

48 C.F.R. Subpart

819.71

(not active)

Veteran-owned small businesses; service-

disabled veteran-owned small businesses

Costs incurred in providing developmental

assistance to protégés may be considered

in determining indirect costs rates for

reimbursement

Evaluation credits during source selection

Factor in evaluating past performance and

determining contractor responsibility

Agency mentoring award (nonmonetary)

Invitation to mentor-protégé annual

conference

Federal Aviation

Administration

FAA Mentor-Protégé

Program available at

http://www.sbo.faa.gov/

MentorProtege.cfm

(active, SBA approval

not required)

Small businesses; small socially and

economically disadvantaged businesses;

small disadvantaged businesses; service-

disabled veteran-owned small businesses;

historically black colleges and

universities; minority institutions;

women-owned small businesses

Evaluation credits during source selection

Subcontracts awarded to protégés count

toward subcontracting goals

Costs incurred in providing developmental

assistance to protégés may be considered

in determining indirect costs rates for

reimbursement

Procurements set aside for firms that are

“participants in the FAA Mentor-Protégé

Program”

National Aeronautics

and Space

Administration

48 C.F.R. Subpart

1819.72

(active, SBA approved)

Small disadvantaged businesses; women-

owned small businesses; HUBZone small

businesses; veteran-owned small

businesses; service-disabled veteran-

owned small businesses; historically black

colleges and universities; minority

institutions; nonprofit agencies employing

persons who are “blind or severely

disabled”

May count costs of development assistance

provided to protégés toward

subcontracting plan

Costs incurred in providing developmental

assistance to protégés may be considered

in determining indirect costs rates for

reimbursement

Eligible to earn separate award fees

associated with the provision of

developmental assistance to NASA SBIR

Phase II protégés

Small Business Mentor-Protégé Programs

Congressional Research Service 19

Agency

Eligible Protégés

Incentives for Mentors

U.S. Agency for

International

Development

48 C.F.R. Subpart

719.273

(not active)

Small businesses; small disadvantaged

small businesses; veteran-owned small

businesses; service-disabled veteran-

owned small businesses; HUBZone small

businesses; woman-owned small

businesses

Costs incurred in providing developmental

assistance to protégés may be considered

in determining indirect costs rates for

reimbursement

Evaluation credits during source selection

Factor in evaluating past performance and

determining contractor responsibility

Agency mentoring award (nonmonetary)

Invitation to mentor-protégé annual

conference

Source: Congressional Research Service, based on various sources cited in Table 1.

a. It is unclear whether “participant” here refers to mentors, protégés, or joint ventures involving mentors

and protégés. Because agencies generally may not restrict competition absent express statutory

authorization, such set-asides may be limited to small business protégés, as opposed to mentor firms.

DOT Funding Recipients’ Mentor-Protégé Programs

Department of Transportation (DOT) regulations authorize recipients of certain federal

transportation funding to establish mentor-protégé programs “in which another [disadvantaged

business enterprise (DBE)] or non-DBE firm is the principal source of business development

assistance to a DBE firm.”

108

These programs are designed “to further the development of DBEs,

including but not limited to assisting them to move into nontraditional areas of work or compete

in the marketplace outside the DBE program, via the provision of training and assistance.”

109

108

49 C.F.R. §26.35(b).

109

U.S. Department of Transportation, “DBE Final Rule, Appendix D to Part 26 - Mentor-Protégé Program

Guidelines,” at https://www.transportation.gov/osdbu/disadvantaged-business-enterprise/appendix-d-to-part-26-

mentor-protege-program-guidelines. Recipients of DOT funding are particularly encouraged to use mentor-protégé

programs to assist DBEs in performing work outside of specific fields in which DBEs are “overconcentrated.” 49

C.F.R. §26.33(b).

Small Business Mentor-Protégé Programs

Congressional Research Service 20

For example, mentors in the Ohio

Department of Transportation

Mentor/Protégé Program may assist

protégés by (1) setting targets for

improvement; (2) setting time tables for

meeting those targets; (3) assisting with

the protégé’s business strategies; (4)

assisting in evaluating outcomes; (5)

assisting in developing protégés’

business plans; (6) regularly reviewing

protégés’ business and action plans; and

(7) monitoring protégés’ key business

indicators, including their cash flow,

work in progress, and recent bids.

110

Those in the Illinois Department of

Transportation Mentor-Protégé Program

similarly may provide training and

development, technical and management

assistance, personnel, financial

assistance, and equipment to their

protégés.

111

According to DOT, data concerning the

number and performance of DBE

mentor-protégé agreements are retained

at the state level and are not reported to

the DOT.

112

The DOT program does not

receive a separate funding appropriation.

Regulations Governing DOT Mentor-Protégé Programs

DBEs may participate in DOT mentor-protégé programs as either mentors or protégés. However,

under DOT regulations, all DBEs involved in a mentor-protégé agreement must be independent

business entities that meet the requirements for certification as a DBE. These regulations also

require that firms be certified before participating as a protégé in a mentor-protégé

arrangement.

113

The relationship between mentor and protégé is based on a written development plan, approved

by the recipient of the DOT funding, “which clearly sets forth the objectives of the parties and

their respective roles, the duration of the arrangement and the services and resources to be

provided by the mentor to the protégé.”

114

The formal mentor-protégé agreement may establish a

110

Ohio Department of Transportation Mentor/Protégé Program, p. 5, at https://www.fhwa.dot.gov/resourcecenter/

teams/civilrights/odot_mentor.pdf.

111

Illinois Department of Transportation, Mentor-Protégé Program Guidelines, at https://idot.illinois.gov/Assets/

uploads/files/Doing-Business/Manuals-Guides-&-Handbooks/OBWD/Mentor-Protege/

Mentor%20Protege%20Guidelines%20Revised%202014.pdf.

112

DOT, Office of Small and Disadvantaged Business Utilization, telephone consultation, March 1, 2011.

113

49 C.F.R. Part 26, App’x D, at C.

114

49 C.F.R. Part 26, App’x D, at (B)(1).

“Disadvantaged business enterprises,” for

purposes of DOT funding programs

Individuals who belong to one of the following racial or ethnic

groups, or who can prove that they are personally socially

disadvantaged, and who have a personal net worth of $1.32

million may qualify as “disadvantaged business enterprises”

upon certification by a state funding recipient:

(i) "Black Americans," which includes persons having origins in

any of the Black racial groups of Africa; (ii) "Hispanic

Americans," which includes persons of Mexican, Puerto Rican,

Cuban, Dominican, Central or South American, or other

Spanish or Portuguese culture or origin, regardless of race;

(iii) "Native Americans," which includes persons who are

American Indians, Eskimos, Aleuts, or Native Hawaiians; (iv)

"Asian-Pacific Americans," which includes persons whose

origins are from Japan, China, Taiwan, Korea, Burma

(Myanmar), Vietnam, Laos, Cambodia (Kampuchea), Thailand,

Malaysia, Indonesia, the Philippines, Brunei, Samoa, Guam, the

U.S. Trust Territories of the Pacific Islands (Republic of Palau),

the Commonwealth of the Northern Marianas Islands, Macao,

Fiji, Tonga, Kiribati, [T]uvalu, Nauru, Federated States of

Micronesia, or Hong Kong; (v) "Subcontinent Asian

Americans," which includes persons whose origins are from

India, Pakistan, Bangladesh, Bhutan, the Maldives Islands, Nepal

or Sri Lanka; (vi) Women; (vii) [a]ny additional groups whose

members are designated as socially and economically

disadvantaged by the SBA, at such time as the SBA designation

becomes effective.

Source: 49 C.F.R. §26.5; and 49 C.F.R. §26.67.

Small Business Mentor-Protégé Programs

Congressional Research Service 21

fee schedule to cover the direct and indirect cost of services provided by the mentor to the

protégé. Services provided by the mentor may be reimbursable if these services and any

associated costs are “directly attributable and properly allowable.”

115

Participant Benefits

Mentor firms may generally count the amount of assistance they provide to their protégés toward

their goals for contracting or subcontracting with DBEs. However, under DOT regulations, a non-

DBE mentor firm cannot receive credit for meeting more than half of its goal on any contract by

using its own protégé.

116

These regulations also prohibit a non-DBE mentor firm from receiving

DBE credit for using its own protégé on more than every other contract performed by the

protégé.

117

For example, if Mentor Firm X uses Protégé Firm Y to perform a subcontract, Mentor

Firm X cannot get DBE credit for using Protégé Firm Y on another subcontract until Protégé Firm

Y first works on an intervening prime contract or subcontract with a different prime contractor.

118

There are no comparable restrictions for other mentor-protégé programs.

Concluding Observations

Congressional interest in small business mentor-protégé programs has increased in recent years

for a variety of reasons, but primarily because these programs help small businesses become

competitive federal contractors which, in turn, creates and retains jobs. Given the Coronavirus

Disease 2019 (COVID-19) pandemic’s widespread adverse economic impact on the national

economy and SBA’s recent merger of the 8(a) Mentor-Protégé Program and All Small Mentor-

Protégé Program, it seems likely that mentor-protégé programs will remain subject to

congressional oversight or proposed legislation during the 117

Congress.

Also, since August 24, 2016, federal agencies sponsoring an agency-specific mentor-protégé

program have been required to report annually to the SBA specific information, such as the

number and type of small business participants, the assistance provided, and the protégés’

progress in competing for federal contracts.

119

This information could prove useful to Congress as

it conducts oversight of these programs.

In addition, Congress could specify additional information that the SBA, and other federal

agencies, must maintain and report annually to Congress concerning their mentor-protégé

programs. For example, DOD has historically been required to report the following information

regarding its mentor-protégé program: (1) the number of mentor-protégé agreements entered into

during the fiscal year; (2) the number of mentor-protégé agreements in effect during the fiscal

year; (3) the total amount reimbursed to mentor firms during the fiscal year; (4) each mentor-

protégé agreement, if any, approved during the fiscal year that provided a program participation

term in excess of three years, together with the justification for the approval; (5) each

reimbursement of a mentor firm in excess of the program’s limits made during the fiscal year,

together with the justification for the approval; and (6) trends in the progress made in

employment, revenues, and participation in agency contracts by protégé firms participating in the

115

49 C.F.R. Part 26, App’x D, at (B)(2).

116

49 C.F.R. §26.35(b)(2)(i).

117

49 C.F.R. §26.35(b)(2)(ii).

118

DOT, “DBE Final Rule, Section 26.35 - What Role do Business Development and Mentor-Protégé Programs Have

in the DBE Program?” at http://www.osdbu.dot.gov/DBEProgram/final/final19.cfm.

119

SBA, “Small Business Mentor Protégé Program,” 81 Federal Register 48590, July 25, 2016.

Small Business Mentor-Protégé Programs

Congressional Research Service 22

program during the fiscal year and protégé firms that completed or otherwise terminated

participation in the program during the preceding two fiscal years.

120

See, e.g., National Defense Authorization Act for Fiscal Year 2000, P.L. 106-65, §811, 113 Stat. 706-10 (October 5,

1999).

Small Business Mentor-Protégé Programs

Congressional Research Service 23

Appendix. Comparison of Selected Agencies’

Mentor-Protégé Programs

Table A-1. Tabular Comparison of Selected Agencies’ Mentor-Protégé Programs

SBA

DOD

DHS

DOT

Primary

focus

Contracts

Subcontracts; suppliers

Subcontracts

Federally funded

contracts

Eligible

mentors

Large and small firms;

agricultural

cooperatives

Prime contractors with at

least one active

subcontracting plan (small

businesses generally

ineligible)

Large prime

contractors

Another

disadvantaged

business enterprise

(DBE) or a non-DBE

firm

Eligible

protégés

Small firms;

agricultural

cooperatives

Small disadvantaged

businesses; businesses

owned and controlled by

Indian tribes, Alaska Native

Corporations or Native

Hawaiian Organizations;

qualified organizations

employing the “severely

disabled”; women-owned

and service-disabled veteran-

owned small businesses;

HUBZone small businesses

Small businesses;

veteran-owned small

businesses; service-

disabled veteran-

owned small

businesses;

HUBZone small

businesses, small

disadvantaged

businesses; women-

owned small

businesses

Small disadvantaged

businesses; women-

owned small

businesses

Notable

types of

assistance

Assistance in

performing prime

contracts with the

government in the

form of joint ventures

Financial assistance in

the form of equity

investments or loans

Subcontracts

Technical or

management

assistance

Advance and progress

payments

Award of subcontracts on a

noncompetitive basis

Investments in protégé firm

in exchange for ownership

interests

Loans

Assistance in general

business management,

engineering and technical

matters, etc.

Rent-free use of

facilities or

equipment; property

Temporary

assignment of

personnel to

protégé for training

Financial and

organizational

management

Overall business

management,

planning, and

development

Technical assistance

Varies by program,

but can include:

training and

development;

technical and

management

assistance; personnel;

financial assistance;

and equipment

Small Business Mentor-Protégé Programs

Congressional Research Service R41722 · VERSION 45 · UPDATED 24

Incentives

for mentor

firms

Assistance counts

toward

subcontracting goals

Can form joint

venture with protégé

that may be eligible

for other small

business contracts

May acquire

ownership of up to

40% in protégé firm

Can receive incentives

in contract

evaluations

Reimbursement of certain

developmental assistance

costs

Unreimbursed development

costs credited toward

subcontracting goals

Can award subcontracts on

a noncompetitive basis to

the protégé

Participation in

mentor-protégé

program can serve

as an evaluation

factor in negotiated

procurements

Costs incurred in

providing assistance

to protégé count

toward

subcontracting goals

Agency award for

best mentor

Can generally count

the amount of

assistance provided to

protégés toward goals

for contracting or

subcontracting with

DBEs

Certain assistance

costs may be

reimbursed

Source: Congressional Research Service, based on various sources cited in this report.

Author Information

Robert Jay Dilger

Senior Specialist in American National Government

R. Corinne Blackford

Analyst in Small Business and Economic

Development Policy

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan

shared staff to congressional committees and Members of Congress. It operates solely at the behest of and

under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other

than public understanding of information that has been provided by CRS to Members of Congress in

connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not

subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in

its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or

material from a third party, you may need to obtain the permission of the copyright holder if you wish to