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Grant writers should recognize the real purpose of NOAA’s “Environmental Literacy Program”

Most social and human service agencies probably won’t notice the recently published National Oceanic and Atmospheric Administration (NOAA) funding opportunity for the “Environmental Literacy Program: Increasing community resilience to extreme weather & climate change” program—how many nonprofits are tracking NOAA, which is probably doing interesting work that is nonetheless not relevant to a typical nonprofit’s workflow? But the “Environmental Literacy Program” is different, and those same social and human service agencies should slow down and look at this one, because the program has $5 million available for 12 grants up to $500,000 to have local community members “participate in formal and/or informal education experiences that develop their knowledge, skills, and confidence” that will help them become knowledgeable about environmental issues.” Oh yeah? What’s that mean, in practice?

Smart nonprofit executive directors who read this description will sit up straighter and think, “walkin’ around money,” because the rest of the description says participants will do things like “participate in formal and/or informal education experiences that develop their knowledge, skills, and confidence to: 1) reason about the ways that human and natural systems interact globally and locally.” In other words, a grantee for this program is nominally going to do some outreach and education, neither of which will be measured. In practice, a grantee will hire a few staff, like outreach workers and peer educators, who are (of course, of course!) going to do some environmental literacy—but they’re also going to be talking to people about what else they need. If there’s a class of 15 low-income youth officially getting “environmental literacy education,” and one mentions that her mom lost her job because the kid’s little brother needs to be watched during the day, the program staff is going to try to hook mom up with a Head Start slot and other supportive services. How else can one stretch these amorphous dollars? Well, environmental education is going to involve practicing reading skills (“What does this sentence about carbon emissions differences between bikes and cars imply?”). A canny nonprofit may do “environmental literacy” and per-capitated tutoring services paid for by a state or county at the same time, using the same staff person. Or, a nonprofit that is losing a grant to provide healthcare navigation services for Medicaid and insurance exchanges may re-train “Healthcare Navigators” to instead become “environmental literacy specialists,” and part of the intake flow for the environmental literacy education will involve checking the status of health insurance: are some participants eligible for Medicaid but not enrolled? Time to enroll them, and make sure their families are on the rolls of the local FQHC. As we’ve written about before walkin’ around money grants are very important because they become the glue that holds the agency together and if effect can be a form of paying for indirect costs.

The funding agency—NOAA—for this program may be unusual, but the ends to which the money will be put are not. This is also the kind of grant opportunity that’s easy to miss, but that we include in our email grant newsletter. Executive directors know that grants like “Environmental Literacy Education” help the doors stay open and the staff stay employed. The official purposes and the true purposes of the grant may differ.

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Links: The hospital monopoly problem, the housing construction problem, and more problems (and some good news)!

* “Hospitals Have Started Posting Their Prices Online. Here’s What They Reveal.” That headline isn’t great, and a lot of hospitals aren’t yet posting prices, because they’ve not been forced to. Still, price transparency should aid in lowering healthcare costs. See also “Hospitals and Insurers Didn’t Want You to See These Prices. Here’s Why,” which is outrageous, but also fascinating. While most people who haven’t had to deal with a mammoth, unexpected healthcare bill, preliminary data show that “hospitals are charging patients wildly different amounts for the same basic services: procedures as simple as an X-ray or a pregnancy test.”

* “A City’s Only Hospital Cut Services. How Locals Fought Back. Apollo-owned LifePoint is embroiled in a dispute in central Wyoming that now stretches to Washington.” Why are the healthcare prices too damn high? Healthcare is the field with real monopoly problems: at least federally qualified health centers (FQHCs) offer alternatives for primary care.

* “ The Housing Market Is Crazier Than It’s Been Since 2006: Limited inventory, low interest rates and bidding wars are driving prices sky-high. ‘It’s just taken a little bit of the joy out of the process.’” We need to build a lot more housing and liberalize zoning laws, so that we’re not stuck in a negative, single-family-only equilibrium—which is where the vast majority of the country is right now.

* “College Enrollment Slid This Fall, With First-Year Populations Down 16%.” One wonders if this will lead to lower tuition costs, but likely not as colleges seem to ignore supply and demand issues.

* “Large variation in earnings returns among postgraduate degrees, with returns of more than 15% for masters in business and law, but negative returns for many arts and humanities courses.” Getting most kinds of masters degrees is a bad choice.

* “The ‘Target Husk’ in Hollywood Opens at Last, 12 Years After Work Began.” We don’t want to collect too many stories about California’s dysfunctions, but this one is impressive: “While the project was supported by then-Councilman Eric Garcetti and a number of community members who turned out at planning meetings, some residents weren’t impressed with the plans. Just weeks after the council’s approval, two lawsuits were filed. While independent, both complaints made similar accusations: that the city had violated rules in granting Target several variances, that the structure was too tall, and that the proposal failed to comply with the California Environmental Quality Act.” If you are wondering why California can’t build transit and lacks affordable housing, this story is a microcosm for those larger issues. Snake Plisken knew this decades ago in Escape from Los Angeles, one of Isaac’s favorite b-movies.

* Stripe now offers carbon sequestration services. Cool!

* Phoenix, the Capital of Sprawl, Gets a Radically Car-Free Neighborhood. The story concerns Culdesac’s development, which sounds incredibly charming.

* “Is This the End of College as We Know It? For millions of Americans, getting a four-year degree no longer makes sense. Here’s what could replace it.”

* “Intellectual Freedom and the Culture Wars.” Compatible with my experiences.

* The NSF has an RFP out called “Smart and Connected Communities:” I find the implication that most communities are, by apparent contrast, dumb and disconnected to be notable.

* Why Ne York’s mob mythology endures.

* “Reinventing Racism—A Review.” Something is likely to replace the college system as we know it.

* Jesse Singal’s book The Quick Fix: Why Fad Psychology Can’t Cure Our Social Ills is coming out soon: you’ll see many social and human service programs implicitly mentioned in it.

* “Amazon, Berkshire Hathaway, JPMorgan End Health-Care Venture Haven: Company had targeted innovations in primary care, insurance coverage, prescription drug costs.” In other words, healthcare reform is so hard that even Amazon doesn’t think it can do it.

* “WhatsApp gives users an ultimatum: Share data with Facebook or stop using the app.” Time to switch to Signal?

* “The People the Suburbs Were Built for Are Gone:” on efforts to build places that are good for humans to live.

* “I helped build ByteDance’s censorship machine.” ByteDance is the parent company of TikTok.

* “Oregon Is Blazing a Psychedelic Trail: A very promising mental health experiment is taking shape in the West.”

* “Telemedicine Will Be Great After Covid, Too: Pandemic-fueled innovations like remote consultation and licensing reform are good for doctors, patients and public health.” That would be nice.

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“Fast Grants,” slow grants, HRSA grants, and COVID-19

In “What We Learned Doing Fast Grants,” Patrick Collison, Tyler Cowen, and Patrick Hsu do something I can’t recall ever seeing any funder, foundation or government, do: write a post-mortem on their giving process and describe what the process has taught them. Their second sentence says, “From the beginning, the institutional response has been lethargic.” I can’t recall ever seeing any funder, foundation or government, emphasize speed: most emphasize process. Speed is rarely a consideration in most grant making efforts—though it should be. Presumably grants are being made to address some critical issue, but what’s being left undone, based on slowness? Most federal grant proposals have an evaluation section, but few, if any, federal funders appear to evaluate themselves.

Most grants, from a funder’s perspective, are about signaling and covering one’s potential downside risk—a point I’ve seen few others make. That works sub-optimally, but seemingly well enough, in normal times. In times of crisis, though, the patterns and habits developed in normal times can be not only dysfunctional, but disastrous. I don’t think the average funder or applicant is much attuned to this issue, which makes me pessimistic about change. Yet the COVID-19 epidemic shows that the costs of overall bureaucratic lethargy is high:

we found that scientists — among them the world’s leading virologists and coronavirus researchers — were stuck on hold, waiting for decisions about whether they could repurpose their existing funding for this exponentially growing catastrophe.” Essentially, no one would, or could, make decisions. Tech companies have evolved the concept of the “directly responsible individual” (DRI): something that government strives not to identify. Without a DRI, no one can be blamed. Notice: “About 10 days after having the original idea, we launched.

The phrase “tech companies have evolved” is key here: evolution is built into the nature of private companies, because the badly managed ones die. One good thing about the nonprofit grant system is that a sufficiently dysfunctional nonprofit will also die, and grant making offers a feedback loop, however tenuous. Universities, though, rarely die. Do they reform? Some of the statements are grimly comical, like: “For example, SalivaDirect, the highly successful spit test from Yale University, was not able to get timely funding from its own School of Public Health, even though Yale has an endowment of over $30 billion.” So while I’ve been critical of government, and the authors are implicitly as well, universities don’t come out looking good either.

The authors report:

“We found it interesting that relatively few organizations contributed to Fast Grants. The project seemed a bit weird and individuals seemed much more willing to take the ‘risk’. (That said, a few institutions did contribute substantial amounts, and we’re very grateful to those that did.)”

I’m not aware of any large foundations that have attempted anything similar, although some likely have, and I don’t know about them. Most grant funding comes from the federal government and, because of the federal government’s sheer size, will for the foreseeable future. Foundations and corporate giving sources have their place—and it’s an important place, as Fast Grants demonstrates—but, barring some kind of major change, we’re unlikely to ever see such sources surpass government grants. The authors say: “[T]here are probably too few smart administrators in mainstream institutions trusted with flexible budgets that can be rapidly allocated without triggering significant red tape or committee-driven consensus.” They’re right.

If you’re interested in the behavior of institutions during the pandemic—which is to say, institutional failure during the pandemic—Michael Lewis’s book The Premonition: A Pandemic Story is excellent. Most government institutions were and perhaps are too used to “business as usual” to respond to business not as usual. FQHCs reacted better than most parts of government, but were hobbled by the usual problems of conflicting information and lack of access to personal protection equipment (PPE) in the early stages of the pandemic.

I’m unaware of any comprehensive accounting of the CDC’s actions or lack thereof during the pandemic, especially one that names names. Most of us know the CDC failed, but not the specifics of the organization’s internal workings. Fast Grants was and is an effort to compensate for government failures and slowness.

In non-emergency situations, science funding can work somewhat well. The Department of Energy’s ARPA-E programs have, going back for more than a decade, accelerated the transition towards low-carbon energy solutions (and we’ve written a lot of ARPA-E grants and SBIRs): but making those decisions slowly won’t kill hundreds of thousands of people, and leave millions hospitalized.

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The latest Service Area Competitions (SAC) from HRSA are here, and the FQHC Shuffle

2020 was a peculiar year for many reasons great and small, one of the small reasons germane to grant writers and Federally Qualified Health Centers (FQHCs) being that HRSA deferred Service Area Competitions (SAC), allowing FQHCs to skip the typical application, or re-application, process. For those of you unfamiliar with FQHCs, they’re the nonprofit healthcare providers that are designed to accept any patient, regardless of ability to pay, and that specialize in Medicaid patients, or helping the uninsured sign up for Medicaid. FQHCs and their counterparts, FQHC Look-Alikes, have significant advantages over typical nonprofit or for-profit primary healthcare providers in that they get higher reimbursement rates from Medicaid, protection from medical malpractice lawsuits, access to the 340B low-cost medication program, and a few other advantages—including eligibility for Section 330 grants via the SAC process, which offer between hundreds of thousands and millions of dollars per year in funding. Every (or almost every) geographical area in the country is supposed to be covered by a SAC and most FQHCs must submit a competitive SAC proposal every three years to keep their Section 330 grants.

Delaying SACs seemed like a reasonable idea during the pandemic, and their return is likely to herald some changes. We talk to lots of FQHCs, and it seems that some of the incumbents are weaker than they were, or discombobulated by the pandemic. Others, however, seem to have been strengthened, particularly those that moved expeditiously to telemedicine, which let them keep up their patient loads, while others have struggled with telemedicine. It’s often not apparent from the outside what’s happening on the inside of FQHCs. Some that may seem weak are likely strong, and vice-versa. That’ll make this SAC season unusual and interesting, and I’d not be surprised to see larger-than-average turnover in SAC grants. Because each SAC covers a specific geography, any new applicant is by definition trying to take over the designation from an existing grantee. We’ve heard the SAC process called “the FQHC shuffle.” Most FQHCs succeed in getting their SAC proposals approved and Section 330 grants renewed, but a significant portion don’t; most of us wouldn’t want to play a game we don’t think we’ll win.

We’ve worked with FQHCs on both sides of the SAC shuffle: incumbents worried about upstarts, and upstarts interested in taking over the incumbents’s service area and Section 330 grants. Losing a Section 330 grant can be an FQHC’s death knell: while SACs typically compose less than 20% of an FQHC’s budget, and often less than 10%, they often function as the glue holding the organization above the water level. Lose the SAC, and the overall revenue decline may be small, but that revenue may also be the revenue that keeps the organization in the black. During uncertain times like the present, an alert organization may be able to make progress that would be more difficult in other times.

Three of the eight planned FY ’22 SAC NOFOs have been issued so far: you can see whether your organization’s service area is up for renewal in HRSA’s massive SAC lookup table. The rest will be issued in the coming weeks or months. Is your FQHC or would-be FQHC ready to act?

Although the pandemic is receding, we’re still living in a strange time: the nonprofit winners have a lot of cash; some nonprofits, however, are gone. The next generation of nonprofit startups haven’t wholly started up yet. This is a propitious time to pursue change. We’ve been talking to a lot of callers about what’s happening in the present and what the future might hold.

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More networking, less working: DHHS’s “No Wrong Door Community Infrastructure Grants” RFP

The Administration for Community Living just issued an RFP for what appears to be a new grant program: No Wrong Door Community Infrastructure Grants, which offers grants “to support the development and enhancement of Network Lead Entities (NLEs) which are providing key access functions within a community such as coordination of information and referral, screening, care coordination, care transitions, eligibility and enrollment, and person centered planning.” If your eyes glaze over and you’ve quit reading already, I understand—all those verbs are abstract, and none say something like “construct new housing” or “offer opioid treatment.” They’re all process objectives and no outcome objectives; applicants don’t need to show or pretend to show that 70% of participants held a job six months after the end of project participation.

But if you’re a wily nonprofit executive director, you’re probably stroking your chin and thinking about whether you can round up a herd of partners to apply. No Wrong Door is mostly of interest because it appears to be a “walkin’ around money” program: applicants spend time “networking” and “building networks,” which usually means taking people out to lunch, holding catered meetings, strolling into other organizations with boxes of donuts, hiring new staff people (who can ideally do some direct service delivery as well, but quietly), and so on. At the end of the project, there’ll be a report describing how amazingly successful all that networking has been, and how the network will strengthen the community’s capacity to do all kinds of marvelous and wonderful things in the future, none of which are measurable. When the funding stops, ideally the staff will be trained to do some other useful stuff for the organization that hired it. That’s why this is walkin’ around money for nimble nonprofits that understand the word salad from the RFP quoted in the first paragraph.

A lot of organizations are really sustained with this kind of “glue” funding, which plugs other revenue gaps and allows it to operate more effectively than it would otherwise. Grants like No Wrong Door help pay for services to people whose reimbursements cover 85% of the costs—not 100%. Don’t be fooled by the No Wrong Door description. If you’re a nonprofit, and you can get some letters of support from the usual suspects in your service area, this is the kind of grant that’s easy to overlook but can be surprisingly valuable.

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“Currently, [Census] data is not loading properly:” DOL’s YouthBuild FY ’21

Needs assessment experts and data nerds know that factfinder.census.gov, the old primary portal into Census data, is dead, while the new census data portal, data.census.gov, is only somewhat alive. Last year, I started a post about the ways that data.census.gov is broken, but I abandoned it because it was too boring, even for me; last year, data.census.gov was hellaciously slow, often taking 10 seconds for a query (a needs assessment may require dozens or hundreds of queries), and many internal links simply didn’t work. Some of that seems to have been fixed: back then, for example, trying to find specific sub-data sets, like educational attainment, for a given zip code, didn’t work. I sent some feedback to the Census contact person, who was very helpful, and eventually most of the problems disappeared.

But not all, it seems; this year’s DOL YouthBuild NOFA includes a humorous instruction regarding data requirements: pages 84 – 86 offer a 20-step algorithm for acquiring poverty data. That the algorithm has 20 steps and three pages is obviously bizarre: instruction 17 notes, “A table will come up showing the Total Population, the Number in Poverty, and the Poverty Rate. Currently, the data is not loading properly and at first only the overall U.S. data will load and you will not be able to scroll any further to the right to see anything else.” Oh? “Currently, the data is not loading properly:” that seems as if it could be the theme of the new Census interface.

About 10 years ago, there was a popular link-sharing site called Digg, and it introduced a now-notorious redesign that users hated, and those users consequently abandoned it en masse, leading to the rise of Reddit, a now-popular link-sharing site. If Digg had been more careful, it probably would have maintained its previous site design for those who wanted it, while introducing its new site design as a default, but not mandatory, experience. And then Digg would likely have iterated on the new design, figuring out what works. Reddit has somewhat learned this lesson; it now has two interfaces, one primarily living at old.reddit.com, which is maintained for people highly familiar with “the old Reddit,” and a newer one that is available by default at reddit.com. This bifurcation strategy allows a smooth transition between interfaces. The Census didn’t follow this strategy, and instead killed the old interface before the new one was really ready. Thus, bugs, like the bugs I’ve noticed, and bugs like those the Dept. of Labor noticed and mentioned specifically in YouthBuild NOFA. The more general lesson is fairly clear: be wary of big user interface changes. If you need Census data, though, you’ll have to use the interface, as is, since it’s the only one available.

For some reason—perhaps latent masochism?—Isaac continues to use MS Office 365 Outlook (not the free version) as an email client, instead of Apple’s Mail.app, or Thunderbird, and he tells me that every time he opens Outlook, he gets an invitation to try “the new Outlook” interface. So far, he’s resisted, but he also points out that most change is positive: when S + A started in 1993, there was effectively no commercial Internet, and the only way to get Census data was to go to Census Office, if you were near a big enough city, city hall, or a large library, where it was possible to thumb through the impenetrable Census books and maps. After a year or two in business, some vendor got the idea of putting the 1990 Census data on CDs (remember those), for quite a high price. Even though S + A was struggling to control costs, he bought the CDs, since they were better than hours in a Census Office or library. But then he had to buy, and install, CD drives in the Pentium PCs (remember those) we used. A couple of years later, he stumbled into a Census data portal set up by a random university, which worked! So, he tossed the CDs. When the 2000 Census came out, the feds essentially copied the university’s interface, creating factfinder.gov, and all was well until data.census.gov came alone. It’ll probably be better than the old interface, at some point.

Complaining is easy and making things better is hard. In the Internet era, both complainers and makers have been empowered, and I appreciate the difference between the two. People who have fundamental responsibility for a product, service, or organization, including the responsibility for making hard decisions that aren’t going to be popular with everyone, have a different perspective than those who can just complain and move on. So I don’t want to be a drive-by complainer, as so many are on “social” media, which seems poisonous to institutional formation and coherence. But, despite those caveats, the instruction from DOL regarding the Census being broken is perversely funny.

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Links: COVID’s effects on mental health, job training in construction, and far more!

* “A Hidden Cost of Covid: Shrinking Mental-Health Services: Mental-health treatment has become harder to find just as the coronavirus pandemic has driven higher demand for such services and hospitals place a high priority on handling the next Covid-19 surge.” This is consistent with what we’ve heard from FQHCs and other mental health provider clients.

* “Prefab was supposed to fix the construction industry’s biggest problems. Why isn’t it everywhere? The Canadian company Bone Structure can produce zero net energy homes months faster than a traditional builder. But its challenges highlight the difficulty of disrupting the entrenched construction industry.” High construction costs have important implications for job-training programs like YouthBuild, several DOL H1-B job training programs, the recent DOL Strengthening Community Colleges Training Grants, and the like: the skills needed in the construction industry are likely to change as modular housing takes off. Notice:

The bigger problem they needed to solve was labor. There have been shortages in labor and skilled tradespeople in the homebuilding industry for years, as workers have fled construction jobs tied to the volatile housing market in the years since the great recession and shifted to higher-paying jobs in other sectors. More than 80% of builders have reported shortages of framing crews and carpenters, according to the National Association of Home Builders. Availability of labor remains builders’ top concern.

If housing developers can’t get skilled persons, they’re going to shift more towards modular.

* “Here’s how DOE’s first crop of risky energy tech has done: Comparing 2009 ARPA-E winners to peers yields a mixed bag.” We’ve written a bunch of ARPA-E, and SBIR/STTR applications, so this one is of particular interest to us. The answer seems to be, “Better than expected” overall. We also seem to have been added to a bunch of SBIR/STTR grant-writer lists, as we’re getting more calls for these projects than we used to. Many startup founders and expert engineers are not writing experts too.

* Rachel Harmon on policing. Much more substantive on this important topic than most of what you’ve read in the media or, worse, on Twitter.

* Don’t believe the China hype. Maybe.

* “Millions of abandoned oil wells are leaking methane, a climate menace.” All energy sources have serious externalities, and relatively few discussions offer an even and total treatment of them.

* Dropbox is a total mess. This matches our experience: we use Dropbox internally but probably won’t indefinitely, due to the said mess. Peak Dropbox was, for us, about five or six years ago, when it was easy to share files with a link but Dropbox hadn’t started putting a bunch of random stuff where the MacOS Finder should be. The simplicity is declining.

* “People Have Stopped Going to the Doctor. Most Seem Just Fine. Do Americans really need the amount of treatment that our health care system is used to providing?” Although I don’t have an immediate citation to this effect, my impression is that people who don’t actively have anything wrong with them don’t need to see doctors regularly—and that includes the elderly.

* Can philosophy make people generous?

* Why does DARPA work? Much more interesting than the title may suggest, and congruent with the link above regarding ARPA-E winners.

* “Losing the Narrative: The Genre Fiction of the Professional Class.” Overstated, yes, but among the most interesting essays I’ve read in a long time, and I read a lot.

* “Aquatic Invasive Species Prevention Activities in Kansas” is (or was) in Grants.gov, and it’s a favorite recent RFP. I’m reminded of Isaac’s fondness for “giant animal” movies (think Lake Placid, Them!, Godzilla, Attack of the Killer Shrews, etc.), although this project is likely for more terrestrial issues.

* How you attach to people may explain a lot about your inner life.

* Licensed to Pill, on the roll from prescribing and prescriptions in the opioid epidemic.

* Might buildings can 3-d print houses—even the roof. See also the second link in this batch.

* “The Underemployment Crisis: Even before the pandemic, roughly one in ten workers wanted to log more hours.” I don’t see how public policy substantially alters this one.

* Zillow research finds that the strength (or weakness) of housing markets is about the same in urban and suburban areas, despite the many stories and claims about “fleeing the city.” But, “Metro-level discrepancies exist as well, especially in San Francisco and New York, showing that not all urban cores are keeping pace with hot suburban markets.”

* “Silicon Valley and Wall Street Elites Pour Money Into Psychedelic Research: Donors raise $30 million for psychedelic nonprofit to complete clinical trials around drug-assisted psychotherapy for trauma.” Coming to an FQHC near you!

* “The Service Economy Meltdown: As companies reconsider their long-term need to have employees on site, low-wage workers depending on office-based businesses stand to lose the most.”

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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.

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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.

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HUD’s Lead Hazard Reduction grant program and the hazards of government autopilot

The NOFA for HUD’s Lead Hazard Reduction (LHR) grant program just came out, and it has $275 million to undertake, as usual, “comprehensive programs to identify and control lead-based paint hazards in eligible privately-owned target housing.” LHR NOFAs are issued every year or two, which is fine, but those of you who are alive and able to read or access the Internet are probably aware that there’s another health hazard out there this year, and it’s a health hazard that’s probably more urgent than lead-based paint—lead-based paint has been illegal in the US since 1980 and HUD’s been funding LHR grants for at least 30 years (we know, because we’ve written so many funded LHR proposals). It’s hard to believe that there’re all that many housing units left in the US with lead-based paint, but HUD soldiers on.

Sure, lead is a health hazard, but COVID-19 is also a health hazard; if I had to bet which one most persons would consider more hazardous right now, I’d bet on COVID-19. $275 million may be a small amount of money by federal standards, but I wonder how much the staff at HUD thought about whether public housing authorities (PHAs) and cities want to work on lead abatement this year, versus how much they’d like and need to work on COVID-19 abatement; $275 million can buy a lot of masks, education, and tests (although tests are still in short supply right now). It’s not really the fault of HUD bureaucrats, since LHR grants have been authorized by Congress for for decades and Congress usually just keeps funding programs like this, no matter what’s going on in the real world. Nonetheless, it would seem to me that a simple, bipartisan vote to amend the underlying legislation would be relatively easy—instead, LHR, at this point, is indicative of the dangers of government autopilot. Autopilot is fine in clear, consistent weather, but it can be disastrous during unpredictable storms—and the world has been hit by a storm in 2020.

I’m not presenting an argument against lead-hazard control: I don’t know enough to say whether lead-hazard control remains, in the absence of a pandemic, a (relatively) good idea or a (relatively—compared to other health-related activities) bad idea. I’ll posit, however, that a lot more people are going to die and suffer from COVID-19 this year, than will die or suffer from lead-based paint, and the failure to change course in the face of new events is evidence of deeper malaise.