Monthly Archives: September 2020

Deciding on the grant proposal structure: ACF’s recent Early Head Start (EHS) application illustrates the challenge

Many RFPs don’t simply and directly state, “Use the following header pattern in your response to the narrative questions.” Why don’t funders tell applicants which header pattern to use? Bureaucracy, legal requirements, funder indifference, signaling: whatever the reason(s), we’ve run into a bunch of program RFPs recently that don’t explicitly state what headers should be used (like the Small Business Innovation and Research grants (SBIRs) we wrote about last week). In structuring responses to confusing RFPs, there are two main schools of thought: one is to use the general headers found in the RFP, and then reply to all the sub-questions in paragraph form. The other school of thought is to use the general headers and every sub-header found either the narrative instructions (if there are any) or the review instructions (if there are any of those). Neither approach is necessarily “right.”

The recent ACF Early Head Start (EHS) RFP, for which we just wrote a proposal, offers a good example of this challenge. Like SBIRs, the EHS RFP has, bafflingly, two sets of narrative instructions: on Adobe page 35, under “Approach” and the other on Adobe page 57, under “Application Review Criteria.” Neither is quite canonical—in other words, the instructions don’t say, in big bold type, “USE THIS HEADER SET.” Instead, ACF offers maddening ambiguity. Perhaps this maddening ambiguity is deliberate, but is more likely due to this fact: the folks who write the RFPs never write the proposals in response and, as bureaucrats, likely they simply don’t care.

Regardless, one has to decide whether it’s better to use just top-level outlines, like “1. Community Need and Objectives, 2. Program Design and Approach,” or sub-header outlines, like “1. Community Need and Objectives, a. the proposed service area and location(s) where services will be delivered.” We chose to mostly follow page 57, while still referencing material on page 35. As with SBIRs, though, there is no 100% right answer, because neither the NIH or ACF give applicants one—but both could reject applications that don’t follow the weakly specified instructions.

Confusing NIH and other Small Business Innovation and Research (SBIR) application guidance

In theory, an “application guide” for a Small Business Innovation and Research (SBIR) grant from a federal agency is meant to make the application process easier: the applicant should presumably be able to read the application guide and follow it, right? Wrong, as it turns out. The difficulties start with finding the application guide and associated RFP (or “FOA,” Funding Opportunity Announcement in NIH-land) . If you go to grants.gov today, Sept. 9, dear reader, and search for “SBIR,” you’ll get 74 matching results—most for National Institutes of Health (NIH) programs, which we’ll use as an example for the sake of this exercise, and because I worked on one recently. I’m going to use “PA-18-705 SBIR Technology Transfer (R43/R44 Clinical Trial Not Allowed)” program, which has download instructions at Grants.gov. When you download and review the “instructions,” however, you’ll find this complication:

It is critical that applicants follow the SBIR/STTR (B) Instructions in the SF424 (R&R) SBIR/STTR Application Guide (//grants.nih.gov/grants/guide/url_redirect.htm?id=32000)except where instructed to do otherwise (in this FOA or in a Notice from the NIH Guide for Grants and Contracts (//grants.nih.gov/grants/guide/)). Conformance to all requirements (both in the Application Guide and the FOA) is required and strictly enforced.

Notice that the URLs in the quoted section are incomplete: it’s up the applicant to track down the true SBIR application guide and correct FOA. I did that, but the tricky phrase is “follow the SBIR/STTR (B) Instructions […] except where instructed to do otherwise.” For the particular NIH application we were working on, the FOA and the Application Guide disagreed with each other concerning how the narrative should be structured and what an applicant needed to include in their proposal. So what’s an applicant, or, in this case, a hired-gun grant writer, to do? With some SBIRs, there is no canonical set of questions and responses: there’s the “general” set of questions and the FOA-specific set, with no instructions about how reconcile them.

To solve this conundrum, I decided to develop a hybridized version for the proposal structure: I used the general narrative structuring questions from the application guide, and I tacked on any extra questions that I could discern in the program-specific FOA. The only plausible alternative to this hybridized approach would have been to contact the NIH program officer listed in the FOA. As an experienced grant writer, however, I didn’t reach out, because I know that program officers confronted with issues like this will respond with a version of “That’s an interesting question. Read the FOA.”

The challenge of multiple, conflicting SBIR guidance documents isn’t exclusive to the NIH: we’ve worked on Dept. of Energy (DOE) SBIRs that feature contradictory guides, FOAs/RFPs, and related documents. It takes a lot of double checking and cross checking to try to make sure nothing’s been missed. The real question is why inherently science-based agencies like NIH and DOE are seemingly incapable of producing the same kind of single RFP documents typically used by DHHS, DOL, etc. Also, it’s very odd that we’ve never worked on an SBIR proposal for which the federal agency has provided a budget template in Excel. In the NIH example discussed above, the budget form was in Acrobat, which means I had to model it in Excel. Excel has been the standard for spreadsheets/budgets since the ’80s.

We (obviously) work on grant applications all the time, and yet the SBIR reconciliation process is confusing and difficult even for us professional grant writers. The SBIR narratives, once we understand how to structure them, usually aren’t very challenging for us to write, but getting to the right structure sure is. For someone not used to reading complicated grant documents, and looking at SBIR guidance documents for the first time, the process would be a nightmare. Making SBIRs “easier” with extra, generic application guides that can be unpredictably superseded actually makes the process harder. This is good for our business but bad for science and innovation.