Monthly Archives: May 2016

First HRSA, Now DOL: Simpler Forms and Reasonable Templates in the FY ’16 YouthBuild FOA

A few weeks ago we noticed that “HRSA made it harder for NAP applicants to shoot themselves in the foot;” now it appears that DOL is getting in the game. In this year’s YouthBuild SGA, DOL includes a form called “WORKSHEET_weighted_average.xlsx,” which models what previous YouthBuild SGAs have only instructed applicants to do regarding unemployment rates. Years ago applicants could do pretty much whatever they wanted regarding unemployment rates, using any data sources, but over time DOL has gotten more and more specific, presumably so that they’re comparing homogeneous numbers.

Today, calculating weighted average unemployment rates isn’t hard, exactly, but we’d bet that DOL got all kinds of interesting, incompatible responses to these instructions, from the 2015 YouthBuild FOA:

The applicant must provide weighted average unemployment rate (rounded to one decimal place) of the combined cities or towns identified as part of the target community(ies) compared to the national unemployment rate as of the latest available comparable data. This data is broken into two youth age subsets: 16 – 19 and 20 – 24. Applicants will have to average the unemployment rate for these two age groups by adding the populations together and then dividing by the total population.

We know how to model this in Excel, but we shouldn’t have had to: DOL should’ve included a template long ago. Last year we wrote a post about how “Funders Could Provide Proposal Templates in Word,” and doing so would likely raise the quality of the average proposal submitted while simultaneously reducing the busy work of applicants. Funders aren’t incentivized to do this, save by the knowledge of what they’ll get if they don’t provide templates, and consequently they don’t.*

Still, there are downsides to the the DOL approach. Applicants must now collect and aggregate specific data points for all the zip codes they’re serving, rather than choosing a different geographical unit, like a city or county, that ordinary humans understand. Few people say, “I really love living in zip code 66666.” But they might say, “Austin is great!”

Those of us who’ve done data work on large numbers of zip codes know how irritating that can be. I’m thinking of a particular project I worked on a couple months ago that had dozens of zip codes in the target area, and I never could figure out how to really expedite the process via the Census’s powerful, yet maddeningly Byzantine, website. There was (and is) probably an efficient way of doing what I was doing, but I never figured it out. The Census website is hardly the first piece of software with fantastically sophisticated abilities that most users never learn because the learning curve itself is so steep.

Overall, though, the simple, included form in this year’s YouthBuild SGA will probably lead to better proposals. We’re a little sad to see it, though, because conforming to the form makes it harder for crafty grant writers like us to weave threads of cherry picked and obfuscated data into an elegant, but sometimes specious, needs assessment tapestry that is coin of our realm.

* Given the unstated role of signaling in proposals, which we write about at the link, funders might be incentivized to make the grant process harder, not easier.

More on Federally Approved Indirect Cost Rates in Developing Federal Grant Proposal Budgets: De Minimus has Arrived

We’ve written about federally approved indirect cost rates before in developing federal grant proposal budgets; I thought there was nothing more to say of this bit of grant writing arcana, but I was wrong.

In general, indirect costs are an agglomeration of “keeping the lights on” costs that are lumped together is a single line item, below the total direct costs in a Federal SF-424A budget form. Since I began writing proposals during Nixon administration,* it was generally necessary for the nonprofit or public agency applicant’s CFO to prepare a “cost allocation plan,” separating the organization’s operating budget into direct costs (e.g., program service staff, client/participant services costs, etc.) and indirect costs (e.g., administrative staff, facility maintenance, etc.).

To claim an indirect cost rate in a federal grant budget, this cost allocation plan must be submitted to the cognizant federal agency, which is the federal department/agency that provides the greatest amount of grant funding to the organization. For example, the cognizant agency for a job training provider would likely be the Department of Labor (DOL), while for an FQHC it would be HRSA.

There’s a Catch-22, however: the organization had to have a federal grant to have a cognizant federal agency to apply to for approval of a cost allocation plan. Thus, non-federal grantees, or ones who never bothered to get an approved cost allocation plan, were basically out of luck regarding indirect costs. There was a workaround: additional line items for administrative costs could broken out. Still, it’s easier to blob a single, indirect-cost line item than it is to include numerous administrative costs, which complicate the budget and narrative while raising uncomfortable questions.

It seems that, while I wasn’t looking, the Feds, and in particular the DOL, has introduced the concept of de minimus into indirect costs. “De minimus” is a Latin expression often used in legal matters to denote something that is too trivial to consider.

We recently completed a DOL proposal for a large nonprofit in a big midwestern city. The client, who we’ve worked for for years, has had lots of federal grants but never applied for an approved indirect cost rate. Since I knew this, I left out indirect costs in the draft budget, putting in a slew of direct cost line items instead. A closer reading of the RFP, however, revealed this nugget:

If you meet the requirements to use the 10 percent de minimis rate as described in 2 CFR 200.414(f), then include a description of the modified total direct costs base.

Apparently the CFR (Code of Federal Regulations) was changed in 2014, allowing a 10% de minimus indirect rate in lieu of an approved rate. Amazing! This old dog has learned a new trick.

Federally approved indirect costs rates can vary from 15% for a small human services nonprofit up to 80% for a university or hospital (think of all the building upkeep, squadrons of deans and hospital administrators, free lunches, etc.). In my experience, however, most Federal agencies will not approve an indirect cost line item more than about 15% for most human services programs, no matter the approved rate. We’ve worked for a large East Cost substance abuse treatment provider that has a Federally approved indirect of 42%, but they never got more than 15% on their federal grants. So the 10% de minimus rate mirrors reality, which is always a surprise in matters relating to the Feds.

* Yes, I’m a geezer.

HRSA makes it harder for NAP applicants to shoot themselves in the foot

Many of you are working on HRSA New Access Points (NAP) applications, and this year HRSA made a revealing change on page 3 of the FOA:

Form 2: Staffing Profile will no longer collect salary or federal funding data to reduce duplication with the Budget Justification Narrative. Fields have been added to collect information on use of contracted staff.

The phrase “to reduce duplication” implies that previous applicants would enter one set of positions in the Staffing Profile and another inconsistent set of positions in the Budget Justification Narrative. Those kinds of errors often lead to rejected proposals—even when the applicant does much else right. HRSA, to its credit, is trying to reduce the potential for such errors by putting salary information in one place, instead of two (or twelve: with the feds, trying to find all the places that must match is often challenging).

We’ve written before about the importance of internal consistency in grant proposals. Internal consistency is one of the most important aspects of a proposal. The other day I met with a client who is a grant-world novice and who provided a recently finished proposal she had written for a technical project concept. We were to use her previous proposal as a starting point for the new proposal we were writing. As we went over the budget, budget narrative, and program narrative of her old proposal, I pointed out several key inconsistencies, and those inconsistencies had likely caused the proposal to lose enough points to become non-fundable. I stressed that internal consistency is more important than perfect fidelity between proposal and project implementation.

Why? Most grant programs have some amount of slack in project implementation—that is, grant applications are proposals, and the actual activities may change (slightly). If you do slightly different project activities or have a slightly different staffing plan, you’ll be fine. With NAP, for example, it’s common for applicants to change sites after they’re funded. They might change a nurse practitioner to a family doc or vice-versa. As long as the funded applicant ultimately opens up a new primary health center and deliver primary health care, they’re going to be okay.

But to get that far, NAP applicants need internal proposal consistency as much as they need to demonstrate site control, even if they snag a different site later. Otherwise they’re unlikely to get funded, making the site issue moot.