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The National Institutes of Health (NIH) grant-making process is slow, even during a pandemic

StatNews reports that the NIH is “a slow-moving glacier” and that the agency’s “sluggish and often opaque efforts to study long Covid draw patient, expert ire.” The news get worse: Congress allocated $1.2 billion to study long COVID, but “so far the NIH has brought in just 3% of the patients it plans to recruit.” The major defense of one NIH employee? The $1.2 billion effort is moving “much faster than we’ve done anything else before” and the NIH’s “usual pace can be even slower.” How reassuring. Unfortunately, the NIH’s Covid-19 response is typical; as we wrote in August 2021, the federal grant-making apparatus is so slow that the private “Fast Grants” initiative attempted to do just what its name implies: make grants fast. And it did: within days at first, and then within two weeks. By contrast, the NIH has never learned how to go fast, and, as far as we can tell, neither have other federal agencies (although HRSA did eventually kick out some telemedicine money faster than we’d have imagined).

Why haven’t federal agencies learned to go fast? I think part of the answer is poor feedback mechanisms. No federal agency goes out of business from moving slowly—no one loses a job, money, or anything else. If even a pandemic can’t shake NIH out of their torpor, what will? A war? Maybe. We couldn’t even bother to make substantial modifications to the absurd clinical trials process during the COVID-19 pandemic, and instead relied primarily on throwing more money at the problem, while NIH continued to crawl at a snail’s pace.

America does the same thing with infrastructure construction: instead of reforming and eliminating bureaucratic rules to reduce the cost of building new infrastructure, we attempt to throw money at the problem until we manage to (partially) bulldozer our way through it. The problems being that the “throw money at it” solution takes way too long, costs too much, and leaves us with too little infrastructure at the end. But there is no single Directly Responsible Individual (DRI) for bureaucratic rules, so nothing changes—much like the stalled COVID study. The StatNews article notes that “A group of two dozen COVID-19 experts recently released a report that excoriated the NIH’s progress as well, noting that recruiting for the study has been painfully slow” and that “The experts argued the Biden administration should create a long COVID task force to hold agencies accountable for progress.” Unless the task force has the power to fire, demote, and restructure, it’s unlikely to achieve much.

Speed is important for many reasons, one being that the faster you can do something, the more you can do of the thing, and the sooner you can get feedback. One sees this feedback process—sometimes called the “Observe, Orient, Decide, and Act” (OODA) loop—in all sorts of endeavors: as the loops tightens, more of the thing gets done, or learned. In computer programming, for example, compiling or deployment that used to take hours or days now happens instantly, allowing for fast feedback to programmers, and letting the programmers get better, fast. Something similar is true in writing: the faster a person writes and gets useful critical feedback, the quicker the revision process becomes (assuming the editor is good and the writer in an improvement mindset).

The opposite is also true: as noted above, our bloated infrastructure rules from laws like the National Environmental Policy Act (NEPA) and California Environmental Quality Act (CEQA) mean that building things like subway or light rail line extension takes a decade and costs billions of dollars. So we build that infrastructure with such agonizing slowness that we never get network effects going, and most people talk of “toy trains” that “go to nowhere,” and, unfortunately, they have a point: if it takes 10 or more years to build a few miles of rail, most people are going to scoff at that rail. The road to improving the U.S.’s transit emissions starts with reforming NEPA. The law is supposedly designed to improve the environment, but instead it locks in the current system, which is not very climate friendly—the law is having the exact opposite of its intended effect.

By the time the NIH completes its studies, the studies might not matter any more. It’s like a person taking five years to decide to ask someone to get married: by the time person 1 asks, person 2 may already be married and have kids. If you wait sufficiently long, opportunities disappear.

Failure to study COVID with sufficient speed will leave people suffering, and possibly dead. That is bad. Despite it being bad, no one seems able or willing to attempt to overcome the problem.

If you don’t think speed and attention matter, try writing anything substantive with interruptions every few minutes: you’ll never get anywhere, and the end result will be unpalatable.

I wish I had a solution to these problems, but I don’t. The normal grant-making process works on a “good enough” basis, and it is typically more about redistributing money to favored communities and populations of focus than truly achieving the nominal goal of whatever the grant-funded program happens to be. Once you realize that, the rest of the system’s apparent peculiarities fall into place. Unless and until Congress wants to make substantial changes to how the federal government works, I think we’re likely to see business-as-usual continue. By far, the most successful part of the federal response to COVID was Operation Warp Speed, which rapidly kicked money to the usual suspects, in the form of pharma companies, and made pre-committments to buy large numbers of vaccine doses even if the clinical trials didn’t work out, such that trials could be conducted quickly and, if the money is “wasted” on ones that don’t work out, that “waste” is trivial relative to the amount of benefit from even a single successful trial.

Warp Speed operated at warp speed, while the NIH is still ambling along in a buggy. That’s been our experience with federal grant-making agencies: they stroll along, and nothing can or will hasten them. That’s a shame, because the country and world face real problems. As with NEPA and CEQA, however, many problems are mandated by legislators, or increased by the rule-making machinery, and no one with sufficient clout seems interested in solving them. These problems also don’t map neatly to right or left ideological talking points. The answer to whether we need “more” or “less” government, for example, is that we need more efficient and effective government, which is neither “more” or “less:” it’s orthogonal to that question, and the solutions aren’t amenable to sound bites.

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Substance Abuse Disorder/Opioid Use Disorder (SUD/OUD): Traditional treatment versus harm reduction for grant writers

We’ve been writing Substance Use Disorder / Opioid Use Disorder (SUD/OUD) treatment grant proposals since 1993, so we’ve been at it for long enough to see waves of funder preferences around approaches come and go. SUD/OUD are hard problems, and made harder because of the misinformation and disinformation about Oxycodone and Oxycontin that Purdue Pharma and its subsidiaries spread for decades, in a way that’s likely worse than the way the cigarette companies once marketed their wares.

For the first 20 years or so in business, the SUD/OUD treatment grant proposals we wrote were usually based on the standard “Step-Down” paradigm, in which people with addiction receive treatment along a continuum of care from a high level of care and then “step down” to lower care levels in increments, leading to eventual recovery and self-care. Following engagement, referral, or self-presentation and development of an individual treatment plan (ITP), the step-down levels are more or less like this:

  • Detoxification/hospitalization
  • Inpatient treatment
  • Intensive outpatient treatment
  • Outpatient treatment, often including 12-Step peer support groups and, for those with OUD, medication assisted treatment (MAT)
  • Recovery and self-care

The levels can be further broken down, but the above is a common schema. As patients move down the treatment continuum, they usually receive case-managed wraparound supportive services—like legal assistance, workforce development, primary/dental care, affordable housing, etc.— at least until they are in recovery and have been “clean and sober” for six to twelve months. The “affordable housing” part has gotten much harder, though, because most cities use zoning laws to restrict the supply of housing, which causes prices to rise, which makes a given housing unit difficult for a grant-funded organization, or a person with drug addiction, to afford. Also, it’s an unfortunate reality that most people with SUD/OUD will relapse multiple times, sending them to the top of the treatment pyramid again. In this way, step-down treatment is something like the classic board game Chutes and Ladders I played as a kid. “Step down” was the main “treatment game” available for decades, although methadone was sometimes used for what we now call OUD.

About ten years ago, we began noticing a difference in SAMSHA, HRSA, and other RFPs for SUD/OUD: those agencies now want usually applicants to augment treatment to include “harm reduction.” As defined and described by SAMHSA, “Harm reduction is critical to keeping people who use drugs alive and as healthy as possible, and is a key pillar in the multi-faceted Health and Human Services’ Overdose Prevention Strategy.” Most of our clients resisted this shift but have gradually gotten on board the harm reduction train as pure harm reduction RFPs, like SAMHSA’s “FY ’22 Harm Reduction NOFO,” began to appear. The shift isn’t surprising, because in grant seeking it pays to follow the golden rule. No, not that golden rule, this one: “The people with the gold make the rules.”

Harm reduction projects usually involve a van-based outreach model in which Peer Support Workers (PSWs) go in teams to what are termed “hot spots” to engage people living with SUD/OUD. “Hot spots” include places like homeless encampments, shelters, parks, etc. The outreach effort can be either obvious (e.g., signage on the van and PSWs in logo t-shirts) or on the down low (e.g., plain white van and PSWs in street clothes), or a hybrid version using magnetic signs placed on the van, or removed from it, depending on the needs of a particular location on a given day. The PSWs distribute harm reduction supplies like clean syringes (with or without exchange), alcohol swabs, sterile water ampules, spoons, fentanyl test strips, sharps containers, and condoms, along with emergency food, clothing, hygiene items, and so forth. The outreach van is also used to provide some direct services in the field like wound care, rapid HIV tests, and naloxone administration.

The most extreme version of harm reduction are safe injection sites: while these are illegal in most of America because the drugs themselves are technically illegal, if widely available, three safe injection sites have recently and prominently opened, two in NYC and one in San Francisco. One key problem with a safe injection site initiative is that few businesses or residents want one near them, much like no one wants to be in proximity of a methadone clinic, so permitting is a real challenge. We’ve yet to write a safe injection site proposal but likely soon will.

A key difference between the standard treatment model and the harm reduction model is that clients are typically not tracked (when Joe or Mary shows up for supplies, their identity isn’t verified and they aren’t entered into a client database for tracking), and, most significantly, services aren’t case-managed. PSWs will offer “warm handoffs” for follow-up treatment like MAT and other center-based services, but there’s no automated follow-up from the harm reduction team.

We’re just grant writers, so we don’t have an immediate opinion as to whether step-down treatment or harm reduction is more efficacious, and most studies on the subject are somewhat questionable, although every treatment/harm reduction proposal we write claims the project design uses “evidence-based practices” (EBPs). When in doubt, claim both “evidence” and “innovation” for your program, leaving aside that those two are often mutually exclusive. If your agency provides SUD/OUD treatment, consider adding a harm reduction component, as this is clearly where the feds are going with grant funds. A cynic might conclude that the feds are pushing harm reduction because it’s much cheaper than providing longitudinal case-managed treatment, but we’ll leave that conclusion to others.

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How to prepare a DOT “Rebuilding American Infrastructure with Sustainability and Equity” (RAISE) application

NOTE: This “how to” post is a companion to “The Dept. of Transportation (DOT) issues first RFP under the Bipartisan Infrastructure Law: Rebuilding American Infrastructure with Sustainability and Equity (RAISE). You should probably read that post first, which was posted yesterday.

The recently passed Bipartisan Infrastructure Law (BIL) has $1T (yes, that’s a “trillion”) for a cornucopia of funding from DOT, DOE, and other Federal agencies. BIL authorizes grants for an array of infrastructure projects, including lead water pipe replacement, high-speed internet, transportation and public transit, airports, passenger rail, electric-vehicle charging stations, electric utility infrastructure, environmental remediation, and the development of time machines (okay, I made up the last entry to see if you’re paying attention).

DOT just issued the first RFP under the new BIL (see note and link above), and a flood of other infrastructure RFPs will be published in the coming months: do as much as can be reasonably be completed in advance, even though you won’t know the specific requirements until the RFP is available. Follow these action steps and you’ll be ready to submit technically correct applications without organizational hysteria as the deadline approaches:

  • Designate a project manager or, as Apple and other tech companies refer to this person, the “Directly Responsible Individual” (DRI).
  • Most funding under the BIL will be for planning and/or development of some sort of physical improvement, structure, or facility. This kind of proposal is very different than a typical human services or R & D proposal: the narrative sections are usually relatively short and often are not composed of a single narrative, but rather are disjointed responses to highly specific questions scattered throughout the RFP; these small narratives may have to be included in different sections of the final application. Severe word or character counts restrictions will likely apply for each narrative section, making it harder to tell a coherent “narrative story” about the project and engage the imagination of the readers who will score the proposal. There should be a section for an abstract or project summary, which may be the grant writer’s only opportunity to draft a topic paragraph that answers the six essential questions that every proposal must include: Who, What Where, When, Why, and How (the 5 Ws and H). If there’s no abstract or project summary, find a place somewhere to include this topic paragraph. The final application, when printed out by the funder*, will look like a layer cake with the narratives interspersed with a myriad of forms, drawings, and exhibits that can easily run to over 200 pages. It is crucial that the RFP application instructions be closely followed, as no matter how great the project concept or the political juice behind it are, the application will not be scored and will be tossed if it’s deemed technically deficient. In most cases, you will not have an opportunity to correct deficiencies.
  • Make sure that your agency can demonstrate site control in the form of a title, right-of-way easement, lease or lease-option. If leased, the term of the lease must be longer than the useful life of the proposed capital improvement(s).
  • Hire an architectural and/or engineering firm to conduct design studies and eventually working drawings needed to obtain a building permit. Due to concerns over climate change and sustainability, select an architect/engineer who will design to meet high-level LEED “green building” standards.
  • Have the architect/engineer develop a master timeline to take the project from concept to moving dirt and establish the critical path for project completion. Once the timeline is set, the DRI should convene the first of a series of “all hands” meetings involving key internal and external stakeholders (e.g., utility company representatives, fire department, etc.). As the project moves forward, keep your eye on the critical path and adjust the timeline frequently. The DRI must keep the project moving forward.
  • Make sure that the architect/engineer interfaces with the jurisdiction’s planning department and/or building department to understand the land use and zoning constraints on the site, as well as the level of environmental review that will be needed. Determine required hearings and discretionary permits/approvals and the anticipated timing of getting the permits/approvals (add these to the project timeline). Depending on the project concept, county, state, and/or federal permits/approvals may be necessary (e.g., EPA, State Office of Historic Preservation “SHPO”, etc.)
  • Have the architect/engineer prepare a conceptual site plan for agency review and, eventually, a second trip the planning/building departments for a reality check. The DRI should schedule any necessary pre-building permit public hearings. The public hearings will need to be formally noticed and widely advertised–these hearings will be where cranky, angry local NIMBYs will show up to complain. No matter how altruistic the project seems, assume that there will be organized opposition and develop a plan to co-opt the opposition or at least address their concerns. We’ve constructed a legal world in which building anything, anywhere, is dragged down by this process, to the detriment of all of us, but Seliger + Associates doesn’t make the rules, we just write the proposals.
  • If feasible, given the project timeline and anticipated RFP release, have the architect/engineer prepare detailed working drawings, based on the conceptual plan (as revised) and apply for a building permit. While not always possible, the best way to demonstrate project feasibility to a funder is having obtained a building permit. This makes it possible to use the ever popular “but for” argument in your proposal: “but for only the grant, the project can be immediately implemented.” This argument is a variation on President Obama’s “shovel ready projects” argument when the 2009 Stimulus Bill was passed.

If all of the above steps are completed, you still won’t have a shovel-ready project; instead, you’ll have an “on the shelf” project and will vastly increase the likelihood of a positive funding decision, as funders for these kind of projects prefer applications that look like they can be quickly started. No funder wants to approve a grant for a project that can’t be built expeditiously—or built at all.

Generally, with an on-the-shelf project, the only step needed after the grant is awarded is to conduct a public-bid process to select the general contractor. A complete application without gotchas and fumbling is the way to soften the stone-like hearts of funder decision makers as they imagine attending the ground breaking ceremony with President Biden and, ideally, Kim Kardashian on hand.

 


* While Seliger + Associates and our readers live in the digital world of 2022, for many federal agencies it’s still 1997. Although most federal proposals are digital uploads, in many cases the proposals are printed out for review and scoring. Thus, all attachments should be 8 1/2″ x 11″ and reviewers will likely view the proposal in grey-scale print outs, not on the 27″ iMacs and 24″ Dell side monitors we use, so beautiful color graphics may be wasted.

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The Dept. of Transportation (DOT) issues first RFP under the “Bipartisan Infrastructure Law:” “Rebuilding American Infrastructure with Sustainability and Equity” (RAISE)

The Department of Transportation (DOT) just issued an RFP for the Rebuilding American Infrastructure with Sustainability and Equity (RAISE) Grants program; this being the federal government, the actual name of this program is the “Local and Regional Project Assistance Program in the Infrastructure Investment and Jobs Act (“Bipartisan Infrastructure Law’)”, which is even longer than the short title we shoehorned into the title of this post. Why have one program name when two will do?

Although RAISE isn’t a new program, this RFP is significant because it appears to be the first one issued under the recently passed “Infrastructure Bill.” While in FY ’20 there was a paltry $1B available for RAISE, this year there’s $1.5B (and yes, that’s “billion”). The max grants are $5M in urban areas and $1M in rural areas, so hundreds of RAISE grants will be made. The RFP says RAISE grants may be used for “surface transportation infrastructure projects that will have a significant local or regional impact.” The deadline isn’t yet published, curiously, but there’ll be an update notice published on Jan. 30 in grants.gov that should have the deadline.

Eligible applicants include states, local governments, transportation districts and agencies—including ports, and Indian Tribes. While nonprofits aren’t directly eligible, they could be part of an applicant consortium and receive sub-grants for things like environmental justice, equity, workforce development, ethnic-specific community outreach and engagement, etc.

RAISE and other transportation programs, new and old, to be funded by the Infrastructure Bill, are really aimed at what is sometimes called the Concrete Lobby. The Concrete Lobby is an unholy alliance of construction companies, developers, local elected officials and appointed bureaucrats, unions, investment banks, lobbyists, chambers of commerce, and similar self-interested parties. In many ways, the Concrete Lobby is an analog of the Military-Industrial Complex that likes politicians who like foreign wars, so the government will buy more bullets. In this case, the Concrete Lobby wants the government to “buy more concrete.”

When I was a Community Development Director for CA cities in the 1980s, we always paid close attention to local Concrete Lobby members because they could easily and often would hand-pick candidates for local office, disrupting planning and redevelopment efforts (despite their efforts, though, local municipalities still severely restrict housing construction). Environmental groups and other NIMBYs typically opposed the Concrete Lobby, using tools like the California Environmental Quality Act (CEQA), the National Environmental Policy Act (NEPA), and State Offices of Historic Preservation (SHPO) to tie up or defeat local development projects, including those aimed at transit and transportation.* We see the results today: traffic gridlock and spectacularly high housing prices that hurt the poor the most, but hurt almost everyone. Depending on how the city I was working for felt about a particular project, we’d either support or surreptitiously attempt to sabotage environmental and NIMBY opposition. If you’re an environmental activist, keep in mind that, while you’re playing a one to five year game, the Concrete Lobby and their sycophants in government are playing a 30 to 50 year game.

With so much grant money now sloshing around looking for transportation projects and the rise of “woke environmentalism,” I’m guessing that the Concrete Lobby will try to co-opt opposition by most environmental groups with visions of subcontracts, as well as the virtue signaling sacraments of environmental justice and the suddenly popular shibboleth of “equity.” If you represent an eligible applicant for RAISE grants or a nonprofit interested in subcontracts, this is the time to look for good project concepts. We’ll soon post a companion article on how to develop a competitive grant proposal for RAISE and its ilk. These kinds of proposals are very different than typical human services proposals as the narratives are short, but the attachments are huge, resulting in what we call “layer cake” applications.


* When I was Community Development Director for the City of San Ramon in the San Francisco East Bay around 1990, we worked hard to get the regional transit authority to add bus lines through San Ramon to connect to the BART heavy rail system. We imagined that our largely upper middle class and progressive residents would love the idea of reducing use of cars for commuting. They were environmentalists, right? Wrong! Within two weeks of the new buses, which were standard size or larger articulated buses, rolling though town, about 200 people in matching anti-bus t-shirts showed up at a city council meeting denouncing the intrusive buses that were keeping them awake at night and “ruining their quality of life.” I had the thankless task of facing this mob. The City Council immediately caved and directed me to renegotiate with the transit authority. The result was to remove most trunk bus lines and add a few mini-buses, which defeated the point of connecting to BART for commuting.

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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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“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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New combo COVID-19 stimulus bill and budget bill have tons of grant “ornaments”

The latest COVID-19 Stimulus Bill was signed into law Dec. 27, which, combined with the FY ’21 budget authorization bill, represents a burst of new grant activity. Congress loves to cobble together fantastically complex budget legislation, as this practice, called adding special interest “ornaments,” gives members lots of room for plausible deniability about voting for them; some of the new discretionary provisions include:

    • $82B for “education,” including $54B for K-12 schools and $23B for colleges/universities. Some of these funds will be distributed on a formula basis, likely via pass-throughs to state education agencies, but the rest should be awarded through competitive RFPs, either direct federal applications or RFPs run by the states.
    • $7B for expanding access to “high-speed internet connections,” including subsidies for low-income families. This provision also include $300M for building out broadband infrastructure in rural areas and $1B for tribal broadband programs. We wrote many broadband infrastructure grants following the 2009 Stimulus Bill during the Great Recession.
    • $70B for a slew of “public health measures,” including $20B for “test and trace” programs and “billions for combating the disparities facing communities of color.” This is another way of saying “walking around money” for nonprofits and local public agencies.
    • $10B for child care providers. We write many early childhood education proposals, including Head Start, Early Head Start, Universal Pre-K, etc., and this set of funding provisions will likely be similar. Furthermore, it’s probable that both non-profit and for-profit entities will be eligible, since much of the non-Head Start child care industry is operated by for-profits.
    • $35B for “wind, solar, and other clean energy projects.” These funds will likely be distributed through the Department of Energy, ARPA-E and similar funding agencies.
    • $400M for food banks and $175M for nutrition programs under the Older Americans Act, which will probably be distributed via programs like Meals on Wheels.
    • $5B for the “entertainment industry,” including cultural institutions like theater groups, museums, etc.
    • $14B for public transit.

Some of the other features, listed here more for amusement than anything else, include: a statement of policy regarding the succession or reincarnation of the Dalai Lama; the establishment of two new Smithsonian museums; giving West Virginia a national park; banning the USPS from mailing electronic vaping products; the decriminalization of various minor violations, including the transportation of water hyacinths, alligator grass, or water chestnut plants across state lines and the unauthorized use of the Swiss coat of arms, the 4-H Club emblem, the “Smokey Bear” character or name, the “Woodsy Owl” character, name or slogan, or “The Golden Eagle Insignia; the establishment of an anti-doping program for horse racing; a bunch of foreign aid programs for things like gender studies in Pakistan; and, my personal favorite, a 180-day countdown underway for the Pentagon and spy agencies to reveal what they all know about UFOs.

In other words, the Mulder and Scully Act of 2020” is hidden in this bill. During a conversation with Tyler Cowen, former CIA director John Brennan recently commented on UFOs, saying that he’s “seen some of those videos from Navy pilots, and I must tell you that they are quite eyebrow-raising” and that, after sifting the evidence, “I think some of the phenomena we’re going to be seeing continues to be unexplained and might, in fact, be some type of phenomenon that is the result of something that we don’t yet understand and that could involve some type of activity that some might say constitutes a different form of life.”

We’ll write another follow-up post or two on this topic, as the 6,000 page bill is fully digested.

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The 2020 presidential election and grants: A tsunami of RFPs is likely, no matter who wins

America is a day away from what one of my adult kids calls, “this shit-show election.” A bit harsh for me, but certainly, as Jerry Seinfeld might call it, a Bizzaro World election. Still, from a grant seeker’s or grant writer’s perspective, a tsunami of RFPs is likely roaring toward us.

Despite media speculation, the amount of grant funds available almost inexorably goes up; this is due partially to the fact that the federal budget is a baseline, not a zero-based, system. The budget for the federal FY ’21, which began October 1, is essentially the FY ’20 budget, with a cost of living bump and whatever Congress added for COVID-19 and pet interests. With the possible exception of the first two years of the Reagan administration, I don’t think there’s ever been an actual, substantial reduction in federal discretionary grant spending. When your read the inevitable NYT or Washington Post story following a Republican victory about looming “budget cuts,” what’s usually being proposed is a percentage cut to planned spending increases—not actual cuts.

Despite endless polls and punditry, no one knows how the presidential and congressional elections will turn out. But consider, from a grant-seeking perspective:

    • By almost any measure, 2020 is the Year of Chaos and upper level bureaucrats (GS 14s and 15s) who run federal grant making agencies are both overwhelmed by the COVID-19 crisis and frozen in place by the last months of this election cycle. Many of the Republican political appointees (Deputy Assistant Secretary for Funny Walks, ect.) are busy updating their resumes, or are busy with clandestine political work. There have been way fewer FY ’21 RFPs issued so far than would normally be the case by this time of year. When the election miasma lifts in a week or two, the federal bureaucracy will be shoveling RFPs out the door to catch up.
    • In the run-up to the elections, the last multi-trillion dollar COVID-19 relief bill wasn’t passed, yet America is experiencing another series of spikes, which will likely lead to more lockdowns and ongoing economic misery. A huge new relief bill will likely pass during the lame duck session, and it will in turn likely be studded with what are called “Christmas ornaments”—special interest funding items placed amid the larger bill components. Some of the basic relief funding, as well as some the ornaments, should result in new discretionary grants—either for existing programs or new ones that Congress dreams up. These RFPs will add to the torrent of already authorized FY ’21 funding.
    • Even if Trump pulls out a victory, there’ll be many new faces in House and especially the Senate, because there are many more contested races than usual this year. It’ll be almost irresistible for the departing members, as well as the ones who survive, to authorize more FY ’21 spending for discretionary grant programs during the lame- duck session. Congress can pass new budget authorization bills at any time, as long as the spending bill starts in the House, and what better time than just before you return home to look for work after losing an election? Almost all polls find, however, that Democrats likely to keep the House, but the Senate is still in tea leaf reading mode.

The coming RFP flood presents real-world challenges for many nonprofits. The first three COVID-19 bills had many programs (meaning, more-or-less automatic funding without an RRP process) for certain types of grant recipients, and especially for healthcare providers like hospitals and FQHCs. This money is running out and, while it has to some extent cushioned the immediate negative impacts of COVID-19, most nonprofit management teams have been thrown into chaos, with disrupted fundraising plans, curtailed local revenue for city/county funded contracts for human services, and layoffs—often at the same time as service demands have increased. Many nonprofits will lack the internal resources or focus to go after new grants, because management is too busy keeping their boat afloat. This is good news for the nonprofits with the energy (or consultants like us) to gin up technically correct grant proposals in next few months, since the competition should be less for any given RFP process.

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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.