111. SUB-CENTER SITE REQUIREMENTS
The federal eligibility requirements of a recipient organization (the Lead Center) does not hold true for SBDC service providers (the sub-centers). With the concurrence of the Lead Center, nearly any organization or combination can host sub-centers thereof, provided that the host demonstrates proof of adequate, secure and continuous funding and commitment to the growth and prosperity of the local SBDC. The Colorado SBDC Network also takes into consideration its goal of statewide coverage.
While it is recognized that each SBDC is a unique combination of resources, sponsors and clients, and therefore unique in its delivery of SBDC services, every local center must meet minimum standards designed to ensure quality service to the state’s business community.
A. POLICIES AND REQUIREMENTS
An SBDC MUST be recognizable as a separate entity from its host institution and be operated as an independent organization. It must be identified as such in all promotional materials, signs and advertising. The SBA, the Office of Economic Development and International Trade (OEDIT) and the host institution must be acknowledged as sponsors in all marketing materials. The CSBDC network logo must be present on all marketing materials. All marketing materials and business cards must have the network standards met that are provided by the Lead Center.
According to SBA policy, all centers must be known as an SBDC or a Small Business Development Center. Local SBDCs shall operate under the names specified in contract with OEDIT. Center names may not be changed without prior written approval of the State Director.
The Colorado SBDC system has been structured so that businesses or individuals can have reasonable access to an SBDC sub-center. A local SBDC must ensure that its site is readily accessible to all business clients in its service area of counties and cities as stated in the contract.
Acceptable office space includes:
Office for the Sub-Center Director where he/she may provide confidential counseling
Acceptable area for use as the SBDC library
To function smoothly and efficiently, a local center must maintain at minimum the following office equipment:
- Copier – Reasonable access to a photocopier is required, preferably located close to the SBDC resource library for client use. SBDCs may charge a nominal fee for client use of copier.
- Computer with Modem and Software – All sub-centers must have at least the minimum required hardware and software configurations to properly support the daily operations of the sub-center, including the necessary resources to operate the Center IC system. The local center must also have Microsoft Word software and access to e-mail. Spreadsheet and financial analysis software is recommended.
- Secure Filing Cabinets – Due to the confidentiality of client information, the local center is required to keep all client case documents in filing cabinets with locks accessible only by authorized personnel. Computers holding MIS and client data files must be secured for authorized personnel only.
B. RECORD KEEPING AND RETENTION
Each center is responsible for collecting and retaining certain data. These data files should be kept in a secure area, accessible only to authorized personnel, for a minimum of three full years. After that time, confidential data must be destroyed by shredding or incineration. Electronic files should be ‘closed’ by adding a ‘closed session’ in the clients Center IC file. All records must be accessible by the Lead Center or SBA for review on-site. Relevant records must also be accessible via remote access through the Colorado Center IC system.
Client Case Files
Each center must maintain hard copy files of client cases OR electronic files via the Colorado SBDC Center IC System. These files may be shared with non-SBDC staff only with the permission of the client and a signed Conflict of Interest Agreement. See Appendix C-1 for the Conflict of Interest Form.
Client folders must be moved to an inactive file if the client has not been seen or counseled for more than 120 days. SBA regulations state that client case files must be kept for three years after becoming inactive and may be destroyed after that time. Client files from a previous year’s files do not need to be kept with current case files; however, they must be stored in a secure place. Refer to Section VI. Counseling, D. Information Collection on maintenance of client files.
Each center must keep files on training events and conferences through the Colorado SBDC Client Management System. These files are not confidential. Please refer to Section VII. Training, C. Information Collection for a more in-depth discussion of procedures for these files.
Accounting reports (detailed general ledgers) include:
- Account statements
- Documentation of in-kind dollars
- Travel reimbursements
Tangible property purchased with federal funds, cash math or program income
Accounting records may be kept by either the accounting or grants management staff of the host institution or with the local Sub-center Director. However, it is required that Sub-center Directors have control of the SBDC budget and accounts. Please refer to Section VIII. Budgets and Accounts for a more in-depth discussion on accounting files.
Personnel files on all SBDC staff must be kept at the local level. These files should include:
- Job description
- Documentation of professional development and achievements
- Hiring process
- Original signed copy of the Conflict of Interest Agreement
- Any other relevant documents
SBDCs should maintain files containing signed Conflict of Interest and Confidentiality Statements for all SBDC staff, volunteer counselors, fee-paid consultants, faculty and students. The Center Director must provide their yearly-signed Conflict of Interest Statements to the Lead Center. Any outside position that could possibly be a conflict of interest must be disclosed to the Lead Center for evaluation. See Appendix C-2 for the Confidentiality Statement Form.
Center correspondence files should include:
- All correspondence to and from the center and/or their advisory boards
- Complaints and follow-up information concerning resolution
All other files necessary for smooth and efficient administrative operations. Centers must abide by all rules of their host institution in this matter.
C. RESOURCE LIBRARY STANDARDS
According to federal rules, SBDCs must maintain current information concerning federal, state and local regulations affecting small businesses and counsel them on methods of compliance. SBA also requires SBDCs to provide and maintain a comprehensive library containing current information and statistical data needed by small businesses. These resources should be made freely available to the public during regular working hours. SBDCs are required to follow all copyright laws. Centers co-located with host institutions are not required to carry those references available in institutional libraries, as long as those libraries are willing to support small business clients.
Federal rules also require centers to maintain lists of local and center private consultants to whom small businesses can be referred. To avoid conflict of interest or the appearance of such, centers should not make specific recommendations. Referral list must offer a minimum of three names and contact information on it.
D. LEGAL REQUIREMENTS
The Code of Federal Regulations (13 CFR) Chapter 1, Small Business Administration, applies to all recipients and sub-recipients of SBA funding. This refers to grants and loans of federal funds, grants or donation of federal property and interests of property. SBA will conduct periodic compliance reviews to survey the practices of recipients. Written complaints will be investigated by SBA and efforts will be made to resolve the matter through informal means. If it is determined that the matter cannot be resolved, action will be taken against the assistance programs. Accordingly, centers need to comply with the following laws. Copies of the CFR information relating to the following topics may be acquired from the Lead Center.
13 CFR Part 112 – Discrimination on Basis of Race, Color or National Origin
No person in the U.S. shall, on the ground of race, color or nation origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination by any business or other activity.
13 CFR Part 117 – Discrimination on Basis of Age
No person in the U.S. shall, on the basis of age, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any business or activity receiving federal financial assistance. Specific discriminatory actions prohibited include: denying an individual any services, financial aid or other benefit provided by the business or other activity on the grounds of age, or limit persons in their efforts to assist in federally funded programs, or treat an individual different from others.
13 CFR Part 145 – Certification Regarding Drug-Free Workplace Requirements
The Office of Economic Development and International Trade certifies that it provides, and will continue to provide, a drug-free workplace. Accordingly, the local SBDCs must ensure that the host institution has notified its employees that as a condition of the grant, the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited in the workplace. Furthermore, it needs to be specified that actions will be taken against employees who violate such prohibition. If an employee is convicted of a criminal drug violation occurring in the workplace, the employee has up to five calendar days to notify the employer, in which time, the employer must notify the Lead Center. The Lead Center will notify the SBA project office within 10 calendar days of occurrence and will discuss appropriate actions.
13 CFR Part 136 – Discrimination on Basis of Handicap
This federal regulation applies to all programs and states that no qualified individual with handicaps shall, on the basis of handicap, be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any program or activity.
Services provided must be equal and as effective to gain the same benefit or to reach the same level of achievement as that afforded to others. Centers may not provide different or separate aid, benefits or service to handicapped individuals than is provided to other individuals, unless such action is necessary to provide qualified handicapped individuals with assistance as effective as those provided to others.
SBA policy requires SBDCs to make modifications and accommodations, which do not fundamentally alter the program or activity or entail undue financial or administrative burdens; to enable otherwise qualified disabled individuals to participate. For practical purposes, centers should keep information on braille/sign language translation services and have office space accessible to individuals with handicaps as part of their strategic plan to comply with these regulations.
E. HOURS OF OPERATION
All SBDC sub-center offices will operate on a forty (40) hour work-week basis, during the normal working hours of the State or host organization, throughout the calendar year. Annual leave, sick leave and holidays shall conform to the policies of the host institution. However, such leave must be arranged to allow for the continuation of SBDC operations, except when there is a total shutdown of the organization facilities where the SBDC is located. All Center Directors must provide dates and times they will be out of the office to the Lead Center. Satellite offices may operate less than forty (40) hours per week, however, the office must have a regular set schedule, which has been approved by the State Director and is available to the public.
Centers are required to maintain publicly listed telephone numbers under the name of the center. To ease accessibility to clients, the publicly listed number should be a direct line to the center. Clients should not have to contact the host institution prior to reaching the SBDC. Telephones should be answered at all times either by a person, answering machine or a voice mail service. When answering the phone, the name of the center should be clearly stated. Phone calls should be returned in a prompt manner.
G. SIGNAGE AND PUBLICATIONS
Signs identifying the SBDC should be placed strategically to make it easy for first time visitors to locate the offices. The network logo must be prominently displayed to recognize the program as part o the network. The format of the logo is provided by the Lead Center. An SBDC must be recognizable as a distinct entity from the host organization. However, the SBDC will acknowledge and welcome the U.S. Small Business Administration and the Colorado Office of Economic Development and International Trade and its local co-sponsors for any and all accomplishments of the SBDC.
According to ASBDC certification standards, SBDCs should make efforts to promote their programs and services to the general public, with emphasis on the small business community. There should be evidence of production and distribution of pamphlets, brochures and audio/video aids for use by small businesses. SBDCs are required to include the Colorado SBDC network logo on its letterhead, annual reports and general brochures. Camera ready copies may be acquired from the Lead Center.
SBA regulations and subcenter contracts require each SBDC Lead Center and Service Centers to feature the SBA logo and/or official acknowledgement of support on all materials produced (either in whole or in part) using project funds (i.e., federal funds, matching funds and/or program income). This requirement does not apply to materials that are not produced using project funds. For purposes of this section, the term “materials” includes, but is not limited to, items such as press releases, brochures, reports, advertisements, training booklets, websites, etc. The term “materials” does not include items such as stationery or business cards.
In addition, while SBDCs must display signage featuring the SBA logo at all facilities open to the public, such signage must also prominently feature the acknowledgement of support identified below. Where used, the SBA logo may be positioned in close proximity to an SBDC’s own logo or may be placed in a prominent location elsewhere in the material. Additionally, whenever an SBDC elects to use the SBA logo, the following statement must appear immediately below or adjacent to that logo:
Funded in part through a cooperative agreement with the U.S. Small Business Administration.
This acknowledgement of support must appear verbatim and may not be altered or replaced with substitute language. However, on materials with severe space constraints such as signs and banners, an SBDC may substitute “SBA” for “U.S. Small Business Administration” in the acknowledgement of support. The acknowledgement of support must be presented in a legible typeface, font size and – where applicable – color contrast.
On materials for which an SBDC does not elect to use the SBA logo, it must at a minimum feature the acknowledgement of support listed above. The SBA logo and/or acknowledgement of support may not be used in connection with SBDC activities that are outside the scope of the Cooperative Agreement. In particular, UNDER NO CIRCUMSTANCES may the SBA logo or acknowledgement of support appear on items used in conjunction with fundraising; lobbying; or the express or implied endorsement of any good, service, entity or individual.
Furthermore, where an SBDC produces materials which feature editorial content, it must use the following alternate acknowledgement of support (either independently or in conjunction with the SBA logo):
Funded in part through a cooperative agreement with the U.S. Small Business Administration. All opinions, conclusions or recommendations expressed are those of the author(s) and do not necessarily reflect the views of the SBA.
The SBDC sub-centers are required to follow the branding guidelines laid out in the SBDC Graphic Standards Manual. See Appendix C-3 for the Graphics Standards Manual.
Parking facilities must have an adequate number of parking spaces and may, as determined by the Lead Center, require reserved space for the SBDC clients. These spaces should be in a well-lit area close to the SBDC.
J. STAFFING REQUIREMENTS
The preferred minimum staff at each SBDC center is an SBDC Director and a dedicated administrative support technician. As warranted by the demand of the service area, SBDCs should expand their staff as needs and resources permit.