Monthly Archives: February 2009

Grant Writing Acronyms Explained and a Bonus in the Omnibus Appropriations Bill

We’ve added a link to “Acronyms” in Grant Writing Confidential’s header. The new page defines and explains many of the fun acronyms used by grant writers, so if you ever read in an RFP or elsewhere that “a CBO has been dispatched for BBQ to IHEs and the DOL ASAP,” you’ll know that “a community-based organization has been dispatched for barbeque needed by the institutes of higher education and the Department of Labor as soon as possible.”

I’ll reiterate what the post itself says: “More acronyms will be added over time; if you have a suggestion, don’t hesitate to e-mail Jake Seliger.”

On an unrelated note, in “Looking at the Stimulus Bill from a Grant Writer’s Perspective” Isaac predicted:

And any programs that get stripped out of the Stimulus Bill will no doubt re-emerge shortly in new appropriations bills after the dust settles and the press corps has moved on to the next crisis.

That was published Feb. 4. Today, on Feb. 24, the Wall Street Journal (WSJ) published “Democrats Unveil Spending Bill for Rest of Fiscal ’09,” which says that “House leaders released a $410 billion spending plan for the rest of fiscal 2009, with increases proposed for long-neglected Democratic priorities ranging from health care to education to public housing.” In addition, “The omnibus package […] would raise overall spending by 8.7% from 2008.” In other words, some programs that the Stimulus Bill missed will probably be funded in the new appropriation bill.

Blast Bureaucrats for Inept Interpretations of Federal Regulations*

Jake received an email response to “FEMA and Grants.gov Together at Last” from a firefighter who is working on a Assistance to Firefighters (AFG) proposal who seems to have been given a bum steer by AFG Program Officer and Jake’s nemesis, Tom Harrington (for background, see “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats” and the hilarious e-mail exchange with Mr. Harrington). According to our email correspondent, Mr. Harrington, the AFG contact person, said that vendors can’t help fire departments prepare grant applications, because he thinks this is forbidden by 44 CFR Part 13.

Is Mr. Harrington correct? A quick review of 44 CFR Part 13 reveals that it concerns uniform administrative requirements for grants to state and local governments. While the section contains lots of fascinating requirements, it is utterly silent on the ethics of who writes or pays for a grant proposal—which is not surprising, since I have never seen any Federal regs or RFPs that would preclude an applicant from getting help in grant writing, paid or volunteer.

While Mr. Harrington seems stuck on 44 CFR Part 13, I think he probably means Office of Management and Budget (OMB) Circular A-87, which covers cost principles for state, local and tribal governments and specifies how Federal lucre is to be spent. A key aspect of A-87 and grant administration in general is that, in addition to following Federal rules, public agencies must hew to their own procurement rules while squandering grant funds. As one who had several local government posts along the way, the most recent being the Community Development Director for the City of San Ramon in the early 1990s, and managed lots of federal and state grant funds, it basically comes down to the “smell test:” if you would not want your mother to read about how you spent Federal funds on the front page of the New York Times, don’t do it.

Federal regs don’t prevent a public agency from receiving grant writing help from others, including a potential vendor, but Mr. Harrington simply doesn’t like the idea and is intimidating AFG applicants by vague threats of dire consequences from scary sounding CFR citations. In other words, Mr. Harrington is probably a bureaucrat bully. Just like Clint Eastwood confronting Gene Hackman’s thugs in The Unforgiven’s saloon scene,** the only way to deal with bureaucratic bullies is to metaphorically blast away by reviewing the regs in question and, when one is satisfied that the threat is an illusion, sweetly asking the bureaucrat to cite chapter and verse to support his position. When he can’t follow through, you’ve got ’em.

Mr. Harrington is probably wrong, but his obstinate response illustrates an important point about dealing with agency contacts in general: although they can give you guidance, what’s written in RFPs ultimately counts. If something a program officer says contradicts the language of an RFP, assume the RFP is right. This can also work against you: if a program officer says that you don’t need a particular form, or that going over the page limit is acceptable, or that you don’t need to follow formatting requirements—all of which might make your life easier—don’t listen. Follow what you can read. Sometimes you’ll find internal contradictions in an RFP, and if so, contact the program officer and cite the conflicts, complete with page numbers and why you think a conflict exists. This may result in a modification to the RFP. But don’t assume that the verbal assurance of someone in the program will count for any more than the paper they’re written on.

Now that I’m satisfied that Mr. Harrington is pursuing his own agenda, rather than providing clear direction based on the regs, let’s examine the underlying ethical issue in juggling these rules and principles. While we do not go out of our way to be hired by vendors to prepare grant proposals for third party applicants, this does happen from time to time. For example, this almost happened with the current Carol M. White Physical Education Program (CMW PEP) RFP, which I blogged about in Brush the Dirt Off Your Shoulders: What to Do While Waiting for the Stimulus Bill to Pass. A large fitness equipment vendor called for a fee quote to have us write CMW PEP proposals for several of their school district clients. I explained that we would be happy to write the proposals as long as the vendor understood we would be working for the school districts, not colluding in getting their products purchased. I pointed out that their products would not be highlighted by brand name in the proposals, and the school districts would still have to follow applicable Federal regs, OMB circulars and their own purchasing rules.

If a vendor wants to try to rig bids, that’s there prerogative and they’ll ultimately be punished. As grant writers, our job is just to write ’em without resorting to unethical acts or breaking laws. To quote Bob Dylan quoting Hurricane Carter regarding how Carter felt about being a boxer, “It’s my work, he’d say, and I do it for pay.” A program officer like Mr. Harrington should no more care about who writes a proposal any more than he should care who fixes the applicant’s plumbing when it backs up. The punch line, of course, is that the vendor didn’t hire us for the CMW PEP, although we have written a few funded proposals under similar arrangements over the years, including one of my favorite Federal programs that is soon to get a huge influx of new money courtesy of the Stimulus Bill: Community Oriented Policing Services (COPS). If an applicant for any grant, however, is concerned about legal and ethical questions, they should ask for an opinion of law from their lawyer, not depend on random off-the-cuff interpretations by program officers.

Mr Harrington’s prejudice against grant writers has a long pedigree. Over the years, I’ve often come across the misguided conception that using an outside grant writer is somehow “cheating.” Way back in 1993 or so, when we were first in business, I tangled with a HUD Deputy Under Assistant Secretary about the then-new YouthBuild program regulations. When he discovered that we were grant writers working for a South Central LA nonprofit, he went ballistic and and accused me of “only wanting to line my pockets.” I responded by asking him if he was a volunteer and if he would like me to request his salary level and travel reimbursements through a Freedom of Information Act (FOIA) request. This calmed him, I got the interpretation of the regs I needed, and the proposal was ultimately funded. In discussing this post with my partner and wife, Kathy Seliger (a lucky woman, she gets to hear my pontifications 24 hours a day), and she pointed that hiring a grant writer is no more cheating than a woman wearing makeup to look her best. If you want to put the best face on your next grant proposal, call a qualified grant writer to apply proposalese makeup to make your application sparkle. While we do sometimes turn down assignments, it is not for the reason imagined by Mr. Harrington, but rather for real ethical problems determined by applying the simple smell test described above. You can also apply the smell test to bureaucrats, and if what they pitch seems wrong, it often is.


* The bureaucrats I am needling in this post are Federal program officers, who are also featured in my last post, Stimulus Bill Passes: Time for Fast and Furious Grant Writing. Not to worry: no Program Officers were actually harmed in the writing of this post.

** The Unforgiven is by far the best modern Western. As Clint’s Bill Munny responds to an accusation of being a “cowardly son of a bitch” for shooting an unarmed bartender in the saloon scene, “Well, he should have armed himself if he’s going to decorate his saloon with my friend” (the dead Morgan Freeman). Words to live by in challenging bureaucrats, who often only arm themselves with self-importance and don’t take the time to understand their own regs.

Stimulus Bill Passes: Time for Fast and Furious Grant Writing

The passage of the Stimulus Bill corresponded almost perfectly with Valentine’s Day, a perhaps unintended but still humorous outcome. While I have not had time to dig through the 1,100 page bill, I know that funding for enough grant programs, new and old, survived to keep grant writers busy, busy, busy. But my topic today is not to peek into the candy store to drool over the tasty funding treats, but rather to consider how the Feds are going to actually shovel $800,000,000,000 out the door.

Since the bill was first proposed, I have been concerned about the logistics of funding distribution and have fired off numerous emails to reporters at the Wall Street Journal, New York Times and Washington Post to try to get them to cover the “how” of the 5 W’s and the H. While I am unsure whether it was a result of my emails, Stephen Power and Neil King, Jr., finally did so with an illustrative piece in the February 13, 2009 issues of the WSJ called “Next Challenge on Stimulus: Spending All That Money.” The reporters take the reader through the tortured process of a Minnesota company trying to access a large Department of Energy (DOE) Loan Guarantee.

Although this company applied during a previous funding round, the Stimulus Bill includes billions more for this initiative, which is supposed to fund the kind of “green, energy-efficient” businesses and jobs that President Obama heralds. As of today, the DOE actually has an open competition for this program. What’s particularly fun is that we happen to be writing a proposal for the DOE Loan Guarantee program. While a non-disclosure agreement prevents me from discussing the project on which we are working, I am very familiar with RFP, which was originally issued on September 22, 2008 with a deadline of December 31—but it was extended to the end of February. I guess the DOE hasn’t gotten the memo from the White House about how growing green jobs helps solve the economic crisis. But I digress.

This RFP is one of the most complicated RFPs I have ever encountered and is filled with confusing directions, references to obscure regulations that are not included in the package, bizarre questions, and so on. It also requires the applicant to produce a dizzying array of attachments, certifications, etc. In other words, the DOE has made it about as difficult as they can to get loan funds, which makes great work for grant writers but presumably discourages applicants. And, remember, these are loans that have to be repaid, not grant funds.

The WSJ story recounts the sad tale of Sage Electrochromatics’ attempts to get its hands on the loan proceeds. Although the loan guarantee was long ago approved, the company won’t see the money until the end of this year at the earliest. The reporters use Sage’s experience to discuss the challenge to be faced by applicants for Stimulus Bill funds. As one who wrote his first funded Department of Energy grant in 1979 during the last energy crisis for the long gone Electric Vehicle Demonstration Program, I know this is not a new situation, as Federal bureaucrats are usually in no mood to work quickly. But the story does raise the specter of what is going to happen, or more likely not happen, when the ink dries on the Stimulus Bill.

Most folks don’t understand and the press rarely covers how, in most cases funds have to be appropriated, regs written, RFPs issued, applications submitted, applications reviewed and ranked, award letters sent out, final budgets negotiated and contracts signed to spend money. The key personnel in this folderol are the small number of Program Officers in the various Federal departments who manage the process. Unfortunately, we don’t have a National Guard of Program Officers who train one weekend a month shuffling papers to be ready to answer the call. That means Federal agencies will find themselves up to their eyeballs in spending authority with existing staff levels pegged at much smaller budgets.

As a result—and despite the best intentions of our President and Congress—it’s going to take quite a while to get the money to the streets. Most Federal agencies usually take anywhere from three to six months to select grantees and probably another three months to sign contracts. My experience with Federal employees is that they work slower, not faster, under pressure, and there is no incentive whatsoever for a GS-10* to burn the midnight oil. Federal staffers are just employees who likely don’t share the passion of the policy wonks in the West Wing or the grant applicants. They just do their jobs, and, since there are protected by Civil Service, they cannot be speeded up. Also, there are no bonuses in the Federal system for work above and beyond the call of duty.

Let’s take my old friend YouthBuild in the Department of Labor, which was transferred out of HUD a few years ago. The deadline for the FY ’09 YouthBuild program was January 15, so there are hundreds of applications sitting under half-filled coffee cups and stale donuts in the sub-basement of the DOL building in various stages of review for the $59,000,000 – $70,000,000 then available (the range comes from Senate/House conflicts in the original appropriations bill). Along comes the Stimulus Bill, which adds $50,000,000. Now we’re talking as much as $120,000,000 for YouthBuild, or well over twice the amount awarded in the last funding cycle in FY ’07.

The question is, what is DOL going to do? It has two choices: (1) more applications that were submitted in January could be funded; or (2) there could be another funding round, opening up the competition and allowing new applications. Logic says door number one, but if I know my federal bureaucrats correctly, door number two will be picked, because this will spread out the work load for the Program Officers and will give DOL time to hire more staff, so that existing Program Officers don’t end up with twice the grantee caseload. Too few Program Officers also increases the potential for fraud, which will already be heightened because of the unprecedented money flood. I’ll let readers know if I am right or wrong.

Of course in addition to more money for YouthBuild and other existing programs, there is funding for lots of entirely new programs, such as the HUD $2,000,000,000 Neighborhood Stabilization Program (NSP), which no one knows how to implement, and $500,000,000 to provide job training through the “Green Jobs Act” under DOL auspices. NSP is in HUD, which means they will have to take staff from the dozens of other competitive HUD grant programs, which are about to issue FY ’09 NOFAs, to hasten this one. When last I visited NSP in December, ‘Tis the Season for Government Folly, Fa La La La La La La La L.A.!, not a single NSP dollar had been spent since the program’s original “emergency” passage in August, and I believe no dollar has yet been spent.

For grant applicants, this means that agencies should apply for as many grants as they can, taking great care to make sure that the applications are technically correct. Since many applicants will believe the stimulus hype and assume that everything will be funded, the majority of applications are likely to be incomplete or incoherent. Because federal reviewers will be told to get the money out as fast as possible, the review is likely to be primarily checklist-oriented, with the Program Officers throwing the garbage proposals over their shoulders. Thus, this is not the time for amateur hour submissions. While it is always important to fly speck your submissions, it will be essential if you want to “have it all.” As the inimitable Vin Diesel says to heart throb Paul Walker in The Fast and the Furious, “If you have what it takes . . . you can have it ALL!”**


* GS refers to “General Schedule” pay grades for Federal employees, which range from GS-1 to GS-15. Most Program Officers are probably GS-8s to GS-11s. Here’s a fun site for calculating GS pay grades. For example, in 2004, a GS-10 working in DC would have made $46,000 to $59,000. The GS-10 is probably stuck in a cubical with a 14″ CRT and Pentium II, along with mismatched furniture, since it is unlikely that any federal managers read about the tools of the trade. This is not exactly a princely sum and probably less than wonderful working conditions—so how likely is it that they will suddenly spring to life to spend the Stimulus package quickly?

** As luck would have it, the original cast has gathered for Fast & Furious, which opens in April. One can only hope that the plot involves Paul Walker getting a Department of Energy grant to build the “ten second car” he owes Vin. After all, electrics have lots of low end torque and street racers only have to go 1/4 mile, so the 40 mile range wouldn’t be a problem. The tag line for the new movie is, “New Model. Original Parts.” This could also be used to describe the somewhat less than successful attempts at changing Washington evident in the Stimulus Bill passage.

FEMA and Grants.gov Together at Last

Last week I complained that FEMA still hadn’t posted the Assistance to Firefighters Grant (AFG) Program 2008 Fire Prevention and Safety Grants to Grants.gov, which particularly rankled after last year’s fiasco.

My post went up on February 1, and lo! on February 2, the FY2008 Fire Prevention and Safety Grants program appeared on Grants.gov. And it only took a single e-mail to FEMA and last year’s contact person, Tom Harrington.

For those of you who are interested, the prodding e-mail I sent said:

Last year, I wrote to Tom Harrington, the AFG contact person, to ask why the AFG RFP didn’t appear in the Federal Register until three days before the deadline. We had an increasingly bizarre exchange about why the delay occurred, in which he gave a wonderfully nebulous response to my pointed questions about who was responsible for posting the announcement to Grants.gov: “I don’t know if there is anyone specific to blame; the process is to blame.” That exchange (see below for the whole thing) became the promised unflattering post on FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats.

This year, the AFG program RFP was released and, just like last year, didn’t appear in Grants.gov. What gives? Did the policy promised by Tom—”As soon as the policy is written, we’ll know. At this time, there is no policy.”—ever get written? If so, by who? If so, why wasn’t it written? This became the latest post on Grant Writing Confidential—FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program—and I would love to write a follow-up with your response.

As you can see from the About Grants.gov page, the site is supposed to be a central storehouse for grants information:

The concept has its origins in the Federal Financial Assistance Management Improvement Act of 1999, also known as Public Law 106-107. Public Law 106-107 has since sunset and is now known as the Grants Policy Committee (GPC). For more information on the Grants Policy Committee, click here.

The Grants Policy Committee’s Final Implementation Plan includes a policy product on page 6 that says one of its products will be a “policy on use of Grants.gov for mandatory grants” which will “Establish [… a] policy requiring agencies to post a description of funding opportunities for mandatory grants on Grants.gov.” Why is the Department of Homeland Security and FEMA hindering that effort?

This year’s unnamed contact person still hasn’t replied, which hurts my feelings, but at least I’ve inspired change you can believe in.

Looking at the Stimulus Bill from a Grant Writer’s Perspective

Since last I wrote about the Stimulus Bill in Brush the Dirt Off Your Shoulders: What to Do While Waiting, the House has passed its version and the bill is staggering through the Senate. It’s amusing to watch various senators say, like Captain Renault in my favorite movie, Casablanca, that they are “shocked, shocked to find pork in the Stimulus Bill.” Just as there is likely to be gambling at Rick’s Café Américain, one is likely to find more than a few curious items in the largest spending bill ever considered by Congress. But, as a grant writer, what interests me is not what politicians and pundits say, since one person’s “stimulus” is another’s “pork,” but what grant programs will shower funds on those applicants nimble enough to gather up the “golden crumbs.”*

I found a pretty good synopsis (warning: .pdf file) of the House’s version of the Stimulus Bill at the website of the D.C. lobbying firm The Ferguson Group.** This handy analysis is organized by Federal agency and program, new or proposed. In looking at this analysis, I focused on the word “competitive,” because this means that eligible applicants will be able to apply directly to the relevant Federal agency, instead of going through some form of local or state RFP process as I described in Getting Your Piece of the Infrastructure Pie: A How-To Guide for the Perplexed. Here are examples of proposed competitive funding:

  • $300M in the Department of Commerce for “Construction of Research Facilities.” Sounds like a winner for colleges and universities!
  • $1B to resurrect the Department of Justice’s Community Oriented Policing Services program, which had been left for dead during the Bush years.*** We wrote many COPS grants during the Clinton years for law enforcement agencies, so this will be like greeting an old friend.
  • $50M in additional funding for another old friend, the Department of Labor’s YouthBuild program.
  • $750M in the Department of Labor for worker training for high growth and emerging industries, along with another $2B to be passed through to states for various training programs under the Workforce Investment Act (WIA) / Workforce Investment Board (WIB) systems.
  • $1B in HUD for capital projects conducted by Public Housing Authorities (PHAs).
  • $4.15B in HUD for two new Neighborhood Stabilization Program (NSP) initiatives. The difference between these two types of NSP grants isn’t clear, but both differ from the NSP program approved by Congress last fall, which is an entitlement program for CDBG-eligible jurisdictions. My guess is that this is an attempt to get “walking around money” to non-CDBG jurisdictions. I know this is confusing, but welcome the to world of grant programs and endless, sometimes overlapping acronyms.

I could go on, but you get the idea. Even better, though, is a requirement in the bill that “competitive grant funding shall be awarded within 90 days of enactment (if there was no funding in FY 2008, then funding shall be awarded within 120 days).” As soon as President Obama signs the bill, the RFPs will be landing like the meteorites in Starship Troopers.

Some of the nuggets in the House version will not survive Senate negotiations—but many will. For a good analysis of current state of the Senate version, see this article in the February 4, 2009 Washington Post, “Senate Lacks Votes to Pass Stimulus: Democrats Trying to Trim $900 Billion Plan to Gain GOP Support” by Shailagh Murray and Paul Kane. Don’t let your heart be too troubled by this piece, however, as our good senators will likely add one program for every one they remove. And any programs that get stripped out of the Stimulus Bill will no doubt re-emerge shortly in new appropriations bills after the dust settles and the press corps has moved on to the next crisis.

My advice is to get ready to rock ‘n roll with furious grant writing. At Seliger + Associates, our Macs are locked and loaded. Let the games begin!


* Tom Wolfe uses golden crumbs as a metaphor in his wonderful novel, Bonfire of the Vanities to describe bond traders, but it also applies nicely to grant applicants. As Sherman McCoy explains: “Just imagine that a bond is a slice of cake, and you didn’t bake the cake, but every time you hand somebody a slice of cake a tiny little bit comes off, like a little crumb, and you can keep that.” Replace “bond” with “federal program” and the same concept applies.

** It’s good to see that The Ferguson Group appears to be thriving in this time of much negative press about lobbyists. I worked closely with Bill Ferguson, the founder and owner, when I was the Development Director for the City of Inglewood in the 1980s. Bill was Inglewood’s lobbyist and I spent lots of time in D.C. with him as I tried to extract various goodies out of the Feds as he built his business.

*** Jake wrote about what he called Phoenix Programs, while I wrote about them in Zombie Funding – Six Tana Leaves for Life, Nine for Motion, so you know that it is not uncommon for the dead program to walk once more among us.

FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program

Last year I railed about the Federal Emergency Management Agency’s inability to post the Assistance to Firefighters Grants program RFP on Grants.gov in a timely fashion in “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats.” In addition, I sent a nastygram to FEMA about this failure, which someone named “R. David Paulison” responded to seven months later, as noted in the third bullet of January Links. That it took seven months to respond to a letter complaining about timeliness might be indicative of further problems.

You might imagine that FEMA would’ve solved the problem this year—in which case you’d be wrong. The Assistance to Firefighters Grant (AFG) Program 2008 Fire Prevention and Safety Grants (warning: link goes to a .pdf) program RFP was issued on Jan. 29, but it’s still not on Grants.gov as of this writing. Furthermore, the RFP doesn’t even include a Catalog of Federal Domestic Assistance (CFDA) number attached—which it should, since, according to the CFDA website, “As you know, the CFDA provides a full listing of all Federal programs available […]” and all federal programs are supposed to have a CFDA number in the body of their RFPs.

(As an aside: the CFDA website isn’t working at the moment because “We are upgrading our site to provide increased transparency, greater access to assistance information and to better support the American Recovery and Reinvestment Plan.” Isaac tried to visit it earlier this week and found it dead. This is somewhat strange because every other website, including ours, would leave the old version up until the new one is ready to go; only the government would take down the old website and leave nothing in its place. I’ve never seen Amazon.com intentionally prevent me from buying books because they wanted to improve the interface. Keep this in mind when contemplating the various proposals that have been floating around regarding government-mandated electronic medical records.)

Nonetheless, a print version of the CFDA lists the AFG’s CFDA number as 97.044. I took that to Grants.gov’s search page and tried the CFDA number and variations on AFG. No dice. In other words, the CFDA and Grants.gov websites must not talk to one another, since AFG appears in the CFDA but not in Grants.gov. More importantly, FEMA still hasn’t posted the AFG RFP to Grants.gov. Maybe FEMA will three days before the deadline, as they did last year. I’m really glad Tucson isn’t susceptible to hurricanes.

But there is some good in this mess, which you can find on page 10 of the RFP: “Applicants are allowed to hire, or otherwise employ the services of, a grant writer to assist in the application process.” Great news! Great, but unnecessary—funders can’t prohibit or forbid grant writers; how you prepare your application is your own affair. Typically, you just can’t charge expenses to a contract before you have a contract to charge them to, and you can’t hire grant writers on a contingent-fee basis. But no ethical grant writer will work on a contingent-fee basis, as we explain in our FAQ.