I’ve been writing grant proposals since dinosaurs walked the earth and have seen various attempts to “reform” the federal grant-making process. Despite the intentions of reformers, there are few actual differences between the Rube Goldberg system I first encountered in the ‘70s and today, other than we use computers instead of typewriters and proposals are uploaded rather than being hard-copy submissions. Still, we have yet another reform effort coming soon (or as is said in Jamaica when you’re waiting for a dive boat, “soon come”).
Congress passed the Grants Transparency Act of 2023 (H.R. 5536), which goes into effect in April 2025. The bill aims to ameliorate the complex nature of the grant application process, as well as the lack of transparency and accountability around funding decision processes, which are currently opaque at best. One of the requirements of the bill is that evaluation criteria (we’ve often written about evaluations) be published in the RFP, although many federal grant-making agencies already do so. The bill requires that if a weighted scoring system, whether qualitative or quantitative, is used to evaluate applications, this system must be described in the RFP. Again, some agencies already do so.
The Grants Transparency Act complements the Grant Reporting Efficiency and Agreements Transparency (GREAT) Act passed in 2019. The GREAT Act requires that federal grant recipients establish and use data standards for information reported to funding agencies. It also requires the Office of Management and Budget (OMB), jointly with executive departments that issue federal grant awards, to establish government-wide data standards for information reported by grant recipients, issue guidance directing federal agencies to apply those standards, and require the publication of recipient-reported data collected from all agencies on a single public website.
Each grant-making agency is charged with ensuring its awards use the data standards for future information collection requests. It does not appear that the data elements have been finalized. A GAO report from January 2024 states that the OMB worked with the Department of Health and Human Services to offer data standards, but these are incomplete, according to the report. A February 2024 OMB memo states that the data dictionary in USAspending.gov serves for now as the initial core data elements.
The 2024 OMB memo also lays out a framework for reducing the burden of applying for federal financial assistance. Included in the memo is a description of the Federal Program Inventory, which is a comprehensive, searchable system providing information on all domestic federal financial assistance programs launched in February of 2024. In addition, the memo includes a staggered process to simplify all RFPs, while reducing their length and increasing the use of plain language in their composition. Furthermore, the memo also describes the changes made to Uniform Grant Guidance. These were released in April 2024 and include several provisions to reduce administrative burden, encourage quality evaluation activities, simplify NOFOs, and level the applicant playing field so that funds are equitably distributed. The recently passed Grants Transparency Bill is the codified effort to simplify NOFOs stemming from changes to Uniform Grants Guidance. Specifically, the changes include but are not limited to:
- raising the threshold value for Single Audits to $1,000,000 from $750,000
- raising the threshold for indirect cost rate to 15% for organizations without a Negotiated Indirect Cost Rate Agreement (NICRA)
- raising the equipment threshold from $5,000 to $10,000 for that which may be sold or retained
- raising the threshold to $10,000 for unused supplies that must be sold following the project period
- raising the maximum amount for fixed-amount subawards to $500,000 from $250,000
- providing direction on the acquisition of waivers to increase federal funds accessibility for tribal nations
- requiring federal grant- and loan-making agencies to use the Federal Program Inventory to provide clear descriptions of their programs
- requiring NOFOs to include an executive summary
- requiring NOFOs to include only essential information and to be shorter in length
- removing the requirement that applications, reporting forms, and notices for grants and loans be in English
- reducing the number of prior approvals needed before spending funds on specific activities
- increasing the emphasis on collecting data and performing evaluations to support quality improvement and community engagement related to the expenditure of federal funds and related outcomes by specifying related costs are allowable and requiring grant-making agencies to report applicant non-compliance
These changes to the Uniform Grants Guidance were required to be enacted prior to October 1, 2024, but agencies had the option to implement them sooner.
Call me cynical, but I doubt any of this will make much of any difference in the real-world grant award process. For example, most RFPs include language along the lines of “the secretary reserves the right to make funding decisions based on geographic and other factors.” What does “other factors” mean? Who knows, but I’ve always assumed this means political expediency for the party in power or perhaps spreading the gold among different ethic groups. Whatever it means, it means that it’s simply not possible for a federal grant applicant to “handicap” their chances of being funded no matter what reforms are implemented.
As long-time grant writing consultants, we know that the most capable applicants try to produce the most competitive/compelling proposals and are far more successful in obtaining, administering, reporting on, and renewing federal funding than their inept peers. A National Resources Defense Council analyst wrote in 2023 that the lowest-capacity organizations eligible to apply for federal funding are the least likely to apply for this funding and higher-capacity organizations are overrepresented among federal applicants and awardees.
Applicant organizations report the following barriers to accessing federal funding: staff capacity, budget size and availability of matching funds, institutional power, lack of experience applying for and receiving federal funds, and lack of administrative capacity to administer large awards. Recent research on the federal grant making process reveals that federal applications take a minimum of 120 person hours. If you’re keeping score at home, S + A can usually produce a high-quality federal grant proposal in about 40 person hours. If it takes your team 120 hours, you’re doing something wrong—hire us or fire your team and find some competent staff.
Specific pain points reported by federal grant applicants include registration requirements in multiple systems, including the overarching System for Award Management (SAM) and the widely used grants.gov WorkSpace portal, which is probably used for about 80% of grant applications. Then, there are the byzantine agency-specific systems like EDGE for Economic Development Administration grants, NIH’s eRA Commons system, and HRSA’s Electronic Handbooks (EHBs) system. Why have one federal application portal, when ten will do? Looks like a good problem for DOGE to solve, since I don’t think the Grants Transparency Act of 2023 addresses this crazy structure for submitting proposals.