23 



Mr. Neal. What we are looking at right now is that we are look- 

 ing at roughly 3 to 4 months before it will be fully operational. 



Chairman Torkildsen. That will be very good news, I think. In 

 your review, do you think that will be sufficient or will other steps 

 be necessary to prevent what is happening? 



Mr. Neal. In our working closely with GAO, because we had 

 started working on it before they had really identified a real time 

 computerized system as being one of the methods that would help 

 cut down on fraudulent activity, we have been discussing with 

 them the characteristics of the system to ensure that the system 

 that we put together would meet many of the criteria they feel 

 would be necessary in order to provide the antifraud deterrent nec- 

 essary for the agencies. 



Chairman Torkildsen. Mr. Rezendes. 



Mr. Rezendes. There are two others that I would add to this list, 

 in addition to a real time system. One is the certification procedure 

 itself The NSFIG is taking a look at the actual form and there 

 may be just a form problem here as well as the company signing 

 on the front page that they are certifying this. There is a whole 

 bunch of attachments to it. It is not really clear from the company's 

 perspective of what they are really certifying to. If the duplication 

 point and disclosure were right above that or in closer proximity, 

 then the cause and effect becomes clearer. 



Second, as I said also needs to be done is some clear definitions 

 as to what is duplication here. It means a lot of things to a lot of 

 people and providing some additional guidance to the applicants as 

 to what we really mean by that. I also think that there is a respon- 

 sibility on the applicant's part to some kind of disclosure. Even if 

 the applicant knows that down deep inside this is not a duplicate 

 research project, it seems to me there is — I would put this in the 

 same category as conflict of interest — there is actual conflict of in- 

 terest and potential or appearance of conflict of interest. 



There should be a disclosure requirement on the part of the ap- 

 plicant to at least disclose where else he has gone with similar type 

 proposals, so the agency can then take appropriate action to deter- 

 mine whether, in fact, these are duplicate or not and whether they 

 want to fund them. 



Chairman Torkildsen. Mr. Neal, comment on those two. 



Mr. Neal. In response to those two items, and as I said we have 

 been working closely with the GAO with respect to this issue, be- 

 cause we want to avoid any appearance of this program's right for 

 fraud. We are in the process of reviewing the GAO recommenda- 

 tions and looking at the certification form and clarifying that and 

 then also developing a definition that will make it much easier for 

 the small businesses to understand that when they submit their 

 proposals that we are looking to avoid any possible duplication of 

 funding at any of the agencies. So, we are working very closely 

 with the GAO in ensuring that that is taken care of 



Chairman Torkildsen. If I could ask also, Mr. Little and Mr. 

 Bassilakis, as users, these steps I think would seem reasonable to 

 you. If you could comment on that and is there anything else from 

 your perspective, so that unscrupulous users do not get into the 

 system to begin with? 



