VI. CONSULTING
Individual advice, guidance or instruction given to a small businessperson or entity is considered consulting. Consulting is a dialogue between a consultant and an individual or business entity, providing value-added service.
Any individual, other than someone purely seeking information, must, prior to entering some relationship with a subcenter, fully complete and sign Form 641. This form can be filled out and signed online through the client online request for consulting (eRFC). See Appendix D-2 for the SBA Request for Consulting FORM 641. To count someone as a client, an individual must receive at least one hour of face-to-face consulting. Additional consulting time can be claimed for preparation time, travel time, and contact time, which includes phone contact or electronic “chatting time” via email as well as face-to-face time. Consulting differs from training in that training is done with groups of clients versus an individual person or business entity. Consulting cannot be counted as training or vice versa see Chapter VII, Training for more information.
A. MINIMUM SERVICE STANDARD
Centers must, in accordance with federal requirements, provide consulting to pre-venture business and exisiting business clients. Only certified CSBDC Consultants can deliver unsupervised consulting to SBDC clients. Refer to Section V, Staffing and Employment Standards. Subcenter directors are responsible to assure that anyone delivering consulting services in their center is certified to do so. Whenever appropriate, pre-qualify nascent entrepreneurs through training workshops before applying one-on-one consulting resources. Centers are also encouraged to take advantage of the Small Business Hotline and can refer individuals looking for information on registering businesses, licensing and other business requirements. No client should be denied normal consulting services and/or pre-required training preparatory to consulting, due to inability to pay a fee. The primary focus of consulting resources should be towards assisting those clients that have the potential to favorably impact the local, state and national economies. Consulting services are unlimited; at no point in time should a client ever be told that he or she has reached a certain “limit” of consulting, whether that limit is in hours or appointments.Â
Recording Consulting Hours
A primary consultant should be assigned to each client case to ensure a single point of contact is in place for the client and to assure only the highest quality of services and information be delivered to that client. It is a requirement that all consulting hours be recorded (including prep time, travel, email, etc) in the Network Client Management System, Center IC, in a timely and accurate manner. If the consultant is unable to input the information into Center IC, they can fill out a 641 consulting form and the sub center director or staff can input the information into Center IC, also in a timely and accurate manner. The first consulting session needs to be a minimum of one hour. See Appendix D-2 for the SBA Consulting Session Form 641. In the event that more than one consultant is in a given session with a client and is seen for one hour, then only one hour of consulting is recorded for that visit. The consultant must assign a main client to the Center IC system. Consulting cases utilizing more than one consultant should only include the allotted time with the client and assign to the main consultant. Notes on the co-consulting can be kept in the detailed information. This allows the local subcenter and the Lead Center to have an accurate picture of the consulting time and productivity for each position paid to counsel. This is a requirement for ASBDC certification.
Group Consulting
Group Consulting is not allowed and is distinguished from training in that each attendee will have individualized work plans as a result. Hours spent on group consulting may not be counted. THis would result in multiple counting of one session. Exceptions can be made for the SBDC ADVANCED Economic Gardening program. These exceptions must first be discussed and cleared by the LEAD Center and State Director.
Client/Case Management
All subcenters are required to have a system in place to ensure all cases are managed to provide excellent customer services and satisfaction. Each client should be assigned a primary consultant who will coordinate their activities, including specialized services from other consultants, training, or other activities of benefit to the client. See the Case Management Book.
Referrals to the Private Sector
In compliance with federal guidelines, clients should be referred to the private sector when they desire someone to produce or perform some aspect of business services for their business on a consistent basis. Examples of such cases are when an accountant, lawyer, or insurance provider is needed or when the client desires someone to write a business plan for them versus being taught those skills. Clients that can afford to pay for services in the private sector or those not meeting SBA size standards should also be referred to the private sector. Any referrals provided by the center to the client for private sector services must include at least three organizations or individuals to avoid the appearance of favoritism.
B. CLIENT RIGHTS AND RESPONSIBILITIES
Subcenters are required to display in their office(s) and/or include in materials provided to client rights and responsibilities statement form. All CSBDC personnel will abide by the policies reflected in this statement. See Appendix F-2 for the Client Rights and Responsibilities Statement Form
C. COMPLAINT PROCEDURES
It is expected that every center will have a written policy for handling any unsatisfied clients. It is the policy of the CSBDC that all clients receive courteous, prompt, thorough and high-quality consulting and service. All complaints handled with a subcenter must be thoroughly documented and kept in a file for periodic review by the Lead Center and federal auditors. This can also be documented in the client’s file in Center IC. If the state office receives a complaint, one of two procedures will be followed.
Easily Resolved Complaints
If the complaint is easily handled with a minimal amount of attention, the Lead Center will listen to the complaint and will assure the individual that steps will be taken to resolve the matter. A Lead Center staff member will then call the subcenter serving the area where the individual is located and request that either the director or a business consultant call the individual directly. It is expected that such referrals will be handled with special attention. The local staff member who handles the complaint should inform the Lead Center staff member by phone, fax, email or written memo when and how the complaint has been resolved. It is anticipated that easily resolved complaints make up nearly 90% of all complaints.
Serious Complaints
If the complaint suggests a problem of a more serious nature, the State Director will first notify the subcenter director and may call the individual with the complaint for further information. The State Director will review session notes on Center IC. The State Director will then request a complete copy of the client case file and ask the subcenter director to write a brief summary of all activity with the client. The State Director will then decide if a reasonable solution can be offered or whether further investigation is required.
If the State Director determines that more information is needed, he/she may set up a personal interview with the individual or a meeting with the client and the subcenter director. If necessary, the State Director may initiate an in-depth investigation of the subcenter in question, including reviewing all cases, personal interviews or requesting an investigation of the office of Inspector General of the U.S. Small Business Administration. It should be noted that serious repercussions could result from such an investigation, including termination or suspension of employment, termination of a contract with a local subcenter or prosecution under applicable state or federal law.
Process of dealing with complaints if the State Director is notified by client: If the State Director is notified by client, she will then read the client file in Center IC. Once this is done, the state director will contact the Center Director to address the conflict. If the conflict is not resolved within a one week period, the State Director may contact the client directly to offer assistance.
D. INFORMATION COLLECTION
Each subcenter must maintain center case files and all client case files within the Center IC System. All SBDC personnel who have access to the Center IC and/or client hard copy case files must sign a “Confidentiality Statement.” See Appendix C-2 for the Confidentiality Statement.
If a client does not fill out the online request for consulting (eRFC) and instead signs a paper 641 form, this form must either be kept in a physical file or uploaded to the client file as an attachment to an info transfer session.
Client Case Files
All client files must be recorded within 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.
Client Online Request for Consulting (eRFC)
When a client fills out the eRFC, they electronically sign the 641, the Client Rights and Responsibilities, the Affidavit of lawful presence, and an optional release of information statement.
If a client does not fill out the eRFC, the center must collect these physical signed forms from the client. These forms can then be uploaded to the client file as an attachment to an info transfer session or kept in a physical file at the center.
After a client fills out the eRFC, it is imperative that the first staff person or consultant to physically meet the client checks the client’s ID and fills in the ‘ID verified by’ box in the client’s Center IC file.
Below is a breakdown of which documents are required to be printed and placed into the physical client file and which documents do not need to be printed and may be stored in or attached to the Center IC system instead.
Forms that must be collected from the client if the client does not fill out the eRFC
641
Client Rights & Responsibilities
Affidavit of Lawful Presence
Closing Cases
Due to the new SBA requirement of Extended Engagement Clients, no clients should be closed out because it would skew/alter the required goal of tracking multi-year clients.
E. EVALUATIONS AND ECONOMIC IMPACT
ASBDC Certification Standards require the following of the CSBDC regarding evaluation of consulting:
- To conduct consulting reports and interviews with past clients
- Review use of procedures to preserve confidentiality
- Use of a system for evaluating the quantity and quality of consulting
- Observe reasonable consultant case loads to ensure timely completion of cases
- Demonstration of a system to analyze the quality and impact of consulting activity, and the relation of consulting activities to the strategic plan and needs assessment
Economic Impact
When obtaining economic impact data during the year, subcenter directors and consultants should use their judgment as to the legitimacy or reasonable assumptions that the positive impact resulted directly or indirectly from assistance or information provided to the client by the SBDC. For example, if a subcenter counsels a client for a total of one hour, it would be unusual for impact created by the client to be the result of SBDC assistance. This is a subjective decision on the part of the subcenter director. These decisions may be examined during on-site reviews. The director must document the impact either via direct statement from the client detailing discussion with client that is dated and timed, written email correspondence with the client, or a time stamped survey response from Center IC. All of these types of proof must be uploaded as an attachment to the client’s session file in Center IC. This will ensure that if ever an “open request” of data, the SBDC has documentable proof of impact.
Impact Verification Process
Client documented impact is due into Center IC two weeks following the end of each quarter, usually falling on the 15th. From the 15th – end of the month, the sub center is not to enter in any impact. During this time the Lead Center verifies that all impact is accurate and that all impact sessions have a verification document attached to the session. The Lead Center then clicks the ‘verified’ box on the client’s session after each session is checked.
Impact Definitions
Historically, CSBDC subcenters have maintained a philosophy of reporting results conservatively. Below are policies affecting the definition of economic impact. Subcenter directors must personally authorize counting impact reported by short-term clients. Subcenter directors should also review impact reported for long-term clients before reporting to the Lead Center for communication to the SBA. Milestones include jobs created, jobs retained, business starts, total loan amount (capital formation), increased sales and procurement contracts.
A baseline figure of the current existing positions and sales within a client’s company, both full-time and part-time must be gathered on the 641 and entered into Center IC. If a client fills out the eRFC and selects ‘in business’, they will be required to enter this information. This information should be verified along with the clients ID during the first face-to-face session. Should the client refuse to provide this information, the client should be accepted and note the refusal in the clients file as an info transfer or miscellaneous session. This can also be noted on the eRFC session.
For the complete list of impact definitions and how to count certain types of impact, see Appendix F-1, Impact Definition Cheat Sheet.
Gathering Impact and Satisfaction Data
The CSBDC uses a variety of methods to gather economic impact data and information about customer satisfaction and client needs.
Gathering Economic Impact Data
Subcenters are encouraged to collect impact using multiple methods and continuously collect impact from their clients throughout the year on an on-going basis. It is required that information be gathered that is consistent with economic development definitions found in the Impact Definition Cheat Sheet mentioned above. All of the methods must include the wording, ‘through the assistance of the SBDC’, when asking clients about reported economic impact. Case managers and consultants should be well versed with the activity of their long-term clients. Ideally, economic development impact avtivity should be reported in the quarter in which it happens or when it is provided to the center. As a consultant becomes aware of the impact, they should record the impact while recording client contact.
Subcenters can collect using the following methods:
- Impact collection survey sent through Center IC
- This is a survey specific to impact collection. It can be sent to any clients who have received 5 or more hours of consulting. This survey can be sent up to twice a year. All answers by clients must be verified by the subcenter Director. Consult the Lead Center if planning on sending out this specific survey more than twice per year.
As part of the Automatic Client Satisfaction Survey
The client is sent an automatic client satisfaction survey after consulting sessions. An impact collection section can be added to this survey. Great care must be taken not to over-report impact or double count impact if a client is filling out multiple surveys in a short time period. All answers must be verified by the subcenter director. More information on the Client Satisfaction survey can be found in the following section.
Impact Verification Form
The client impact verification form can be given to a client to fill out any time during prior to or following a client consulting session. This form may vary from center to center, but should coincide with the impact fields listed in Center IC. This form is signed and dated by the client. It is then uploaded as an attachment to the client session notes. See Appendix F-4 for sample Impact Verification Forms.
Email follow-up with client
A sub center Director, staff member, or consultant can send a follow-up email to a client at any time to collect impact. This email exchange must include the wording, ‘through the assistance of the SBDC….’. The email exchange is then uploaded to the clients session notes along with the recorded impact. Calls can be made to the client as well, but there has to be a follow up email or signed document that is then uploaded to the client session.
Chrisman Study
ASBDC certification standards require the CSBDC to take part in the nationwide economic impact study to ensure national state-based comparison of network capability. The CSBDC has traditionally contracted with James Chrisman, along with the rest of the nation’s SBDC Networks. The study is done yearly for ASBDC. This study is sent out through Center IC to all clients who had 5 or more hours of consulting in the previous year. Any economic impact data collected through this survey is automatically uploaded to the client’s file. It reflects in the prior year’s economic impact data.
Client Satisfaction Surveys
Multiple forms of client satisfaction surveys are conducted by the CSBDC, including evaluations collected after every consulting and training session, a mailed form 1419 survey and a random sample telephone survey conducted by the Lead Center. See Appendix F-3 for a Sample 1419 Survey. Detailed guidelines for the submission of monthly consulting and training evaluation tallies can be found in Section 10 of the Policy and Procedure Manual
- Standardized statewide evaluation forms must be distributed and collected at the end of every training event and consulting session. These forms are then tallied by month and submitted to the Lead Center. See Section 10 of the Manual for more details.
- Form 1419 will be mailed to every continuous consulting client twice a year by the Lead Center in February and July of each year. The Lead Center will tabulate all forms and generate a statewide report and individual site reports. it the subcenter would like to mail additional 1419s, coordination with the Lead Center is necessary to avoid duplication of client surveys.
- If Network goals have not been met, the Lead Center may also conduct an annual random telephone survey of all clients who received more than five hours of consulting assistance during the previous year. The number of clients contacted will be determined by the number of total clients with five or more hours of consulting at each center to ensure that the results are statistically significant for each subcenter.
- All participants in the Colorado Leading Edge program are surveyed at the end of each program. Instructors must survey participants at the end of each class series.
- The CSBDC participates in the ASBDC’s national survey of clients with five or more hours assistance two years prior to the year of surveying (the Chrisman Study). These figures are incorporated into a national result study of continuing satisfaction and long-term results. Results of the national survey are provided to subcenters as soon as they are received from ASBDC.
Subcenters must survey their clients at the end of each training and consulting session. If it is determined that less than 50% of clients are completing surveys, subcenters may be subject to reprimand and/or program audit from the Lead Center. These surveys are a form of need assessment and to evaluate clients’ immediate satisfaction with CSBDC services.
