Category Archives: Government

Bad news in new tax bill for nonprofits that depend on small- to medium-sized donations

I recently wrote about Bad and good news for FQHCs in the latest Republican tax bill, and last week, the Republican tax bill passed under its official title, “Tax Cuts and Jobs Act” (TCJA). Like it or not, the TCJA is now law and I’m continuing to look at its implications for nonprofits and grant seeking. As reported by the Washington Post, “Charities fear tax bill could turn philanthropy into a pursuit only for the rich.”

Why? The combination of doubling the standard deduction and limiting the deductibility state/local taxes and mortgage interest will likely significantly reduce charitable donations by middle and upper middle income Americans. Those people would need very high deductions to bother itemizing, so many won’t. That’s very bad news for smaller to mid-size nonprofits that depend on donations.

Unlike businesses, which can enter new markets and develop new products, nonprofits have relatively few revenue possibilities (the main ones they do have are listed at the link). In addition to grants and fee-for-service contracts (e.g., foster care, substance abuse treatment, homeless shelter beds, etc.), these are limited to membership dues (for member organizations like Boys & Girls Clubs, animal rescues, etc.), fundraisers, and donations. The latter three will be impacted by the TCJA.

While every nonprofit executive director dreams of landing a donor “whale,” mega-donors are not only rare but tend to give to larger and well-connected nonprofits (the rarely acknowledged “swamp” of philanthropy, if you will). The booming stock market and lowered corporate tax rate will likely to produce more whales, but many of these will donate to corporate or family foundations—not garden variety human services nonprofits toiling away in relative obscurity. We’ve had many conversations with executive directors whose nonprofits are doing good work but find it hard to translate “good work” into “increased donations.”

Nonprofit executive directors will have to make a choice that will become more acute in 2018: cast off in the whale boat to search for Moby-Dick or chase schools of small donation fish. The former strategy is usually pointless and the later is time consuming work that will become harder as many Americans realize that there won’t be a tax deduction reward because they won’t itemize.

The silver lining is that foundation portfolios are being engorged by the historically high bull market. They’ll also receive huge donations from corporations and the upper-income people, who will get much of the direct benefits from the TCJA. No matter what, foundations must distribute 5% of their assets every year, and we offer foundation appeals in part with that in mind to clients.

Also, federal spending on discretionary grant programs continues to rise and most states should see increased tax revenue, some of which will be allocated to grant programs. As budgetary chaos subsides, federal agencies will resume normal RFP patterns.

Language update for grant writers: the CDC has a new list of seven forbidden words/terms

The Washington Post reports that “CDC gets list of forbidden words” from its political masters. We find it hard to judge how serious the list is, because knowledge of the ban itself is only by way of “an analyst who took part in the 90-minute briefing”—not exactly an authoritative source for final policy. Still, the article has been making the rounds and the supposedly forbidden terms are “vulnerable,” “entitlement,” “diversity,” “transgender,” “fetus,” “evidence-based” and “science-based.”* As grant writers, we’re always sensitive to the vagaries of evolving language and ideas, as you can see from our 2014 post “Cultural Sensitivity, Cultural Insensitivity, and the ‘Big Bootie’ Problem in Grant Writing.”

(EDIT: It appears that “After firestorm, CDC director says terms like ‘science-based’ are not banned.” Alternately, it’s also possible that the word ban was being discussed, but the reaction to the leak caused the CDC to can it.)

While most PC language emerges from the political left, this CDC directive comes from the Trump administration. There’s a bit of humor in this, as right-wing commentators often cite the PC “language police,” raising the dire specter of Orwell’s 1984 and his 1946 essay, “Politics and the English Language.” It seems the wingtip is now on the other political foot.

Still, the CDC banned words are standard proposalese that we frequently use in CDC, HRSA, and many other proposals. Some combination of these words are also found in virtually every RFP. “Evidence-based practice” (EBP) is so ubiquitous as to be cliché, even though RFPs rarely define what is supposed to constitute a given EBP. I find this true: “When I see the words used by others, my immediate reaction is to think someone is deploying it selectively, without complete self-awareness, or as a bullying tactic, in lieu of an actual argument, or as a way of denying how much their own argument depends on values rather than science.” People who understand EBPs just cite the evidence and let the evidence speak for itself; people who don’t use the term EBPs as a conceptual fix-all.

Despite the putative ban, grant writers should continue to use these buzzwords, because proposal reviewers—both federal program officers and peer reviewers—expect to read them. Reading them is a good substitute for thinking about what they mean. In addition, there’s often a disconnect between the political appointees (e.g., Deputy Under Assistant Secretary for Obscure Grant Programs), who nominally run federal agencies, and the career civil servants or lifers who actually operate the agencies. Lifers often refer to the political appointees as “the summer help,” since they come and go with new administrations—or more frequently. Peer reviewers are practitioners, who are likely to be PC in the extreme and unlikely to attend to most administration instructions. As grant writers, our audience is composed of reviewers, not the summer help, so that’s who we’ll continue to write to.

For those of us of a certain age, it’s also ironic that the CDC picked seven words to ban, instead of six or eight, given comedian George Carlin’s 1972 monologue “Seven Words You Can’t Say on Television.”


* Mother Jones has a parody of this kerfuffle with seven replacements for the banned words: vulnerable=snowflake, entitlement=welfare, diversity=anti-white, transgender=deviant, fetus=unborn child, evidence-based=elitist, and science-based=atheist.

Bad and good news for FQHCs in the latest Republican tax bill

The Senate passed their version of the Republican tax bill early Friday morning, setting the stage for a conference committee with the House to reconcile their previously passed bill this week. A tax “reform” bill only comes along about once in a generation, making this important. We don’t post partisan political material here, so I’m not talking about the politics of the Republicans finally notching a significant legislative win; rather, we’re looking at the bill’s impact on the real world of FQHCs and Medicaid.

The Senate version of the bill repeals the individual mandate to buy health insurance. Most press analyses over the weekend indicate that the House will likely go along. As reported by Washington Post, this turns Obamacare Marketplaces from mandatory to voluntary:

The Congressional Budget Office, the official nonpartisan estimator, has predicted that this change would cause health insurance premiums to rise by about 10 percent a year and prompt 4 million people to drop insurance by 2019 and 13 million to drop it by 2027.

There are plenty of other estimates of what repealing the mandate will do, but over time it will almost certainly destabilize the Exchanges/Marketplaces and individual insurance landscape. The impact on FQHCs is likely to both bad and good (maybe that’s true of most complex legislation, which are usually drafted by “K Street lobbyists”).

First, the bad news: One impact of Obamacare has been a dramatic increase in the number people enrolled in Medicaid, because of the expansion of Medicaid eligibility in most states, as well as HRSA funding for an army of FQHC-employed “navigators” to enroll patients in Medicaid. FQCHs were originally intended to serve uninsured and underinsured people, not Medicaid enrollees. Still, most FQHCs have become the de facto Medicaid providers in their service areas, since many FQHC service areas have few primary care and specialty care providers and fewer still that will accept new Medicaid patients. Keep in mind that Medicaid is insurance, not health care; like all health insurance, it is only as good as the patient’s ability to find a provider who accepts Medicaid.

Without going to mind-numbing detail, Medicaid is essentially a joint federal/state-funded, fee-for-service program that reimburses providers for service encounters. As more Americans with Medicaid seek care from FQHCs, the FQHCs are faced with same dilemma confronting all providers—Medicaid payments may not and often do not fully cover the cost of providing certain encounters. Like all businesses and nonprofits, FQHCs have to “make money” to keep the lights on. FQHCs have several advantages over other nonprofit and for-profit providers, including enhanced Medicaid (and Medicare) reimbursements.

Still, an FQHC has to run a tight ship not to go into a Medicaid reimbursement death spiral. The more Medicaid patients an FQHC has, the larger this challenge becomes, and the tax bill will likely result in FQHC’s getting a flood of new Medicaid patients, as well as uninsured patients bailing from Marketplace plans, when the mandate ends. FQHCs are “providers of last resort” and in theory can’t refuse care, regardless of a patient’s lack of insurance or ability to pay. All FQHCs have sliding fee scales for this purpose, but, once again, they have to be well-managed to cover the cost of sliding fee scale-payers, including no-payers.

Now for the good news: In addition to reimbursements from Medicaid and other third-payers, FQHCs also receive annual Section 330 grants. As we’ve written about before, Section 330 grants account for about 18% of FQHC revenue and Section 330 grants don’t depend on the number of Medicaid or self-pay/no-pay patients served. This built-in cushion will help FQHC weather the consequences of the Republican tax bill.

Over time, lobbyists for the National Association of Community Health Centers (NACHC), the FQHC trade group, and their affiliated Primary Care Associations in each state, for example the California Primary Care Association (CPCA), will go to work. This will likely result in larger Section 330 grants, specialized grants to cover the impact of the tax bill, increased New Access Points (NAP) grant competitions, or a combination of all three. Although mostly forgotten in the media, FQHCs received a huge increase in funding under the 2009 Stimulus Bill and ACA (Obamacare) legislation. I don’t see any reason why this won’t repeat itself in 2018, as the impact of the tax bill on insurance, health care access, and FQHCs becomes clear.

Some version of Obamacare is likely here to stay and FQHCs will be the primary mechanism for providing care to Medicaid and uninsured people for the foreseeable future.

In other healthcare news, CVS (the drug store) plans to buy Aetna (the insurance company). This is a seemingly unusual pairing, and at first glance I don’t know what to make of it, save to think that we’re seeing unusual times and strange alliances in the healthcare industry.

Grant writing during an economic boom: primary health care, substance abuse, homeless services, job re-training, and foundations

In 2010, I wrote “Grant Writing from Recession to Recession,” and last week the Bureau of Economic Analysis announced that GDP increased by 3% in each of the last two quarters. The stock market is rocketing upward.

This post is the obverse of my 2010 post; while grant seeking and grant writing are eternal, they’re different during economic lows and highs. As we’ve written many times before, nonprofits typically derive revenue from a mix of donations, membership dues, third-party reimbursements (e.g., Medicaid, substance abuse treatment, etc.), fee-for-service contracts (e.g., foster care, home health care, etc.), government grants, and foundation grants.

As the economy takes off, nonprofits will see increased donations, fundraising revenue, and/or membership dues, as people either have more disposable income or think they do. Still, it’s a shortsighted nonprofit that puts too many revenue strategy eggs in the donation / fundraising / membership dues basket—any number of impossible to predict black-swan events could occur, or the economy could just fizzle back into the slow growth pattern of the recent decade. Donations and membership dues could disappear in a flash, just like they did in 2008 – 10.

Nonprofits that provide some kind of heath care should see a big uptick in third-party reimbursements and fee-for-service contracts, particularly regarding Medicaid services (FQHCs for example), opioid-use disorder (OUD) treatment, and HIV services. Despite eight years of political posturing, it looks like some version of Obamacare and expanded Medicaid is here to stay. Also, with more Americans now dying annually from ODs than car crashes, there’ll be big increases in funding for OUD treatment and HIV services, since HIV transmission is closely linked to the injection drug use that is at the center of OUD.

This brings us to grants. Despite rumors, the Trump administration and Republican congress have not decreased federal funding for discretionary grant programs. The FY ’18 Federal Fiscal Year began on October 1. Since 1998, Congress has funded the federal government via a series of Continuing Resolutions (CRs), rather than passing actual budgets. In general, CRs use a “baseline budgeting” concept, which means that the FY ’18 CR, which just passed Congress last week, mostly continues funding levels for discretionary grant programs from the previous CR, adjusted upward for inflation.

Since every Federal program has a strong lobby and highly paid lobbyists, Congress rarely makes significant, real spending cuts. Instead, if anything happens, Congress might restrict the rate of federal spending growth—but not adjust the underlying, baseline level. Funding for the NEA, public broadcasting, etc., will not be eliminated or even reduced. These parts of the government are popular symbolic targets, but virtually all of the growth in the federal budget comes from Medicare, Social Security, and Medicaid. Any budget hawk that doesn’t propose reductions to the first two is simply not serious.

There are actually more federal grant dollars up for grabs in FY ’18 than in FY ’17. The same will be true for grants from most states and big cities/counties, as tax revenues will climb with the rising economic tide. Counterintuitively, there’ll probably be less competition for most RFPs. With the better economy, some nonprofits will forgo submitting competitive grant proposals, choosing to pick the new low hanging fruit of donations, membership dues, and fundraising. Smart nonprofits will, however, go after every plausible government grant opportunity, since there’s no good reason not to and some organization is going to get the grants.

In the coming years, the big grant opportunities will likely be in primary health care, substance abuse treatment, Ryan White services, homeless services, and job re-training. One of the oddities of America at the moment is that homelessness continues to increase, despite a pretty good economy. Many cities, like Los Angeles, Seattle, San Francisco have passed, or proposed, big new local taxes to fund homeless services, in addition to the federal McKinney Act Programs through HUD. With respect to re-training, despite low unemployment rates, about 90 million working age Americans remain out of the workforce for reasons ranging from former incarceration to less than catastrophic disabilities to outmoded work skills or something.

The workforce must adjust to the rise of robots and AI-related manufacturing and services, which means lots of grants will be available for job training and re-training project concepts. Nimble nonprofits, who traditionally have been involved in such services as housing, prisoner reentry, family support, after school programs, teen pregnancy prevention and the like, would be wise to change their missions to go where the money will be.

Foundation grants will also be a good target. By federal law, foundations are required to spend at least 5% of their endowments annually on grants. With the huge stock market run, foundations will be flush with investment earnings that must be distributed through grants. Go get ’em tiger.

L.A. digs a hole more slowly than economics fills it back in: The Proposition HHH Facilities Program RFP

As newsletter subscribers know, last week the City of Los Angeles released the “Proposition HHH Facilities Program FY 2017-18 Request for Proposals for the FY 2018-19 Bond Issuance.” That program is an excellent opportunity for nonprofit and public agencies looking for capital funding. There was $85 million available in 2016, and this year there may be more. Even better, grants to $3.5M are up for grabs.

Prop HHH funding is a great opportunity for nonprofits involved in homeless services, since it provides capital funding for facilities, which don’t have to including housing units. As we’ve written before, facility grants are usually much harder to get than grants for the services provided at the facility. Also, the RFP states:

The Prop HHH Facilities Program is intended to fund the acquisition and/or improvement of real property for facilities (hereinafter referred to as “project(s)”) that provide services or goods to, or otherwise benefit, persons experiencing homelessness, chronic homelessness, or at risk of homelessness (hereinafter referred to as “homeless”).

The key phrase is “at risk of homelessness,” which makes almost any LA human services provider potentially eligible for a Prop HHH grant, not just traditional homeless services providers. This is because clients of most L.A. human providers are well below 200% of the Federal Poverty Guidelines (FPG). Given the very high rents in LA, this means they likely pay well over the federal/state/local standard of housing affordability of 30% on gross income for housing costs (e.g., rent, utilities, etc.).

From a grant writing point of view, this means they’re pretty much all all at risk of homelessness. Whether obvious or not, many of these clients are, have been, or will be episodically homeless (e.g., living in cars, motels, family members, shelters, etc.).

From a larger perspective, though, Prop HHH is also like digging a tiny hole in the housing affordability problem, while the rest of L.A.’s rules and regulations act as a dump truck filling that hole back in. You may ask what that means. One good explanation comes from Reddit, of all places, as this architect explains why virtually all new housing units in L.A. are “luxury” units. As he says, “EVERYTHING built in LA is defined by parking, whether we like it or not.” Moreover:

In making our assessments as to required space for parking, the typical calculation is that each full parking stall will require 375sf of space (after considering not just the space itself but also the required drive aisle, egress, out of the structure, etc. So that 800sf apartment is actually 1175 sf to build. [. . .]

So not only is 32% of your apartment just for your car and otherwise useless, but its also by far the most expensive part of that apartment to build.

It’s not possible to build enough housing for middle-income people in L.A., let alone low-income or homeless people, because of parking and outdoor space requirements. The City of L.A. is doing useful work for a handful of nonprofits with Prop HHH, but unless the City changes its parking requirements, there isn’t much real change that’s going to happen. The high cost of free parking is real. In the proposal world, though, none of these problems and trade-offs exist. In the real world, however, a couple hundred million dollars to build a couple hundred units (or even a thousand units) isn’t going to do much for homelessness in a city of four million and a metropolitan statistical area (MSA) of twelve million. In 1970, L.A. was zoned for ten million people. Today, with our vastly inferior technology, it’s zoned for four million and change. Until the city fixes zoning, it’s not going to fix homelessness.

Basically, it’s impossible to build enough housing for people in L.A. because it costs so much to also build housing for cars.* As grant writers, however, we love to see new programs like Prop HHH that’ll provide “walkin’ around money” for LA nonprofits.


* Seattle is a little better off, but it still has many perverse zoning issues, which I wrote about comprehensively in “Do millennials have a future in Seattle? Do millennials have a future in any superstar cities?” The short version of that highly detailed article is that many cities severely restrict housing supplies; in the face of rising demand, this raises the cost of housing.

HRSA sort of “Streamlines” FY ’18 Service Area Competition (SAC) NOFOs

As happens every year about this time, HRSA has been issuing Service Area Competition (SAC) Notices of Funding Funding Opportunities (NOFOs). As we’ve written before, HRSA requires Federally Qualified Health Centers (FQHCs—otherwise known as Section 330 grantees) to compete every three years against non-grantees to keep their Section 330 grants. About one-third of the approximately 1,400 FQHCs must submit a technically correct SAC proposal every year.

We’re in the early stages of the FY ’18 SAC derby and, while the process is more or less the same this year, we came across this, on page 3 of this year’s NOFOs:

The Project Narrative has been streamlined to reduce applicant burden, more closely align with Health Center Program requirements as defined by statute and regulation, and simplify the collection of information.

(Emphasis added.)

Sounds great in theory, but let’s take a closer as what passes for streamlining in HRSA-land. The term “NOFO” replaces HRSA’s longstanding practice of calling their RFPs Funding Opportunity Announcements (FOAs). Thus, HRSA has replaced one pointless three-letter acronym with a similarly pointless four-letter acronym. In they had to change the acronym, why not just use the more common acronym “RFP?”

The FY ’17 SAC FOAs were 73 single-spaced pages, while the FY ’18 NOFOs are 67 single-spaced pages (NOFO length does not include the 365 single-spaced Service Area Announcement Table). It also doesn’t include the 66-page, single-spaced HRSA SF-424 Two-Tier Application Guide (love the doc name). The Guide has intricate formatting instructions for all HRSA grant submissions but often conflicts with the instructions with particular NOFOs, like SAC. Then there’s the voluminous underlying regs for the Section 330 program, but counting these pages would like counting grains of sand on Santa Monica beach.

In summary, HRSA has shaved six pages off of the 498 pages of instructions, not counting regs, or a generous 1.2%! We must applaud HRSA for this Herculean streamlining effort!

To be fair to HRSA, some items previously required of all applicants, like floor plans, no longer must be submitted by current grantees. Also, current grantees don’t have to answer a few of the repetitive questions in the Program Narrative. Still, the SAC applications may not exceed 160 pages “when printed by HRSA.” Despite the digital application upload process, HRSA still prints and copies proposals for reviewers to read in hard copy—partying just like it’s 1999. This is a good reason to avoid color graphics in federal proposals, as most will be printed and copied in grayscale for reviewers.

For FY ’18, HRSA also still requires a two-step application process: the first step in a relatively simply application uploaded through grants.gov, while the second step is the fiendishly complicated online application through HRSA’s Byzantine Electronic Handbooks (EHB) system.

Without doing a deep dive into the SAC NOFOs, a couple of features remaining in the FY ’18 NOFOs illustrate why HRSA using the term “streamlined” might be euphemistic.

There’s a convoluted section of the Project Narrative called “Governance,” where applicants must explain how their governance structure meets complex Section 330 requirements. For current grantees—some of which have received SAC grants for decades—this is odd, since these applicant couldn’t have been funded before if they didn’t meet these requirements. Also, even current grantees must upload copies of their articles of incorporation and bylaws as attachments. One would think that after, say, four SAC grants, HRSA probably doesn’t need another copies of the Owatonna Community Health Center’s articles and bylaws (I made this up, but there probably is a FQHC in Owatonna, MN).

Also, in addition to the grants.gov application file, Abstract, Project Narrative, and Budget/Budget Narrative, the EHB application includes 13 required forms and 12 required attachments for all applicants, including existing grantees.

LAHSA’s Continuum of Care (CoC) RFP illustrates the challenge of handling RFP amendments

Last week I wrote about challenge of handling RFP Amendments, and I observed that local RFPs tend to have more amendments than state or federal RFPs. Right on schedule, the Los Angeles Homeless Services Authority (LAHSA—the Continuum of Care entity for LA County) illustrated the point.

On August 3, LAHSA published the FY ’17 RFP for New CoC projects to provide services to people experiencing episodic or chronic homelessness,* with an August 14 deadline. Then LAHSA almost immediately began issuing a series of amendments (we’re up to three) and one clarification (so far). If you’re the grant writer applying for a CoC project, you not only have to deal with a surprise deadline only 11 days away and the complexities of writing a proposal that conforms to both the LAHSA RFP and the underlying HUD FY ’17 CoC NOFA (notice of funding availability; this is HUD-speak for RFP), but also the stream of amendments. Since no one has hired us to write the proposal yet, I haven’t looked closely at the amendments, other than to see if the deadline has been extension. Tomorrow we might still get a late-breaking amendment that extends the deadline. C’mom LAHSA, go for it!


* Free proposalese language update: In the last year or so, we’ve noticed a change in the language used in many human services RFPs. There are no longer any homeless persons in America. Instead, there are “persons experiencing episodic or chronic homelessness.” Try using that phrase 20 times in a ten-page proposal.

Grant writing help series: Tips for handling RFP amendments

We’ve written many times about contradictory and occasionally incoherent RFPs. To add to the grant writer’s burden, government funders often issue amendments—sometimes right before the deadline. The feds are less prone to issue amendments than local funders; as one moves down the food chain to state and county / city funders, the potential for amendments increases greatly. I’ve got no idea why this is, but it is.

We’ve seen a bunch of important RFP amendments in projects we’ve worked on lately, and those got me thinking about the issue. Here are some handy tips for handling RFP amendments:

  • If possible, sign up to receive email notifications. This is fairly easy in the federal system but highly variable at the state and local levels.
  • Remember your last visit to the DMV or DMV website? Government notification systems are not the same as you’ll find at Amazon, FedEx, or even Fandango. Since the system may be unreliable, you should go back to the funder web site several times before the deadline to check for amendments, even if you’ve signed up for notifications.
  • When you find an amendment, review it carefully, as the notice, if there is one, may not be complete or even accurate. Among items to look for are a deadline extension, clarification of confusing or contradictory RFP language, changes in the required proposal format (e.g., max page/character lengths, order of responses, fonts, etc.), additional requirements (e.g., new forms or budget instructions, new letters of commitment, changed required attachments, etc.). The best way to do this, assuming you have at least two large monitors, like our offices, is to put the RFP on one monitor and the amendment on the second. Go through the amendment, finding each relevant section of the RFP, and mark-up the RFP. Then, make sure your draft—no matter what stage it is in—matches both the RFP and amendment. If you find yet another conflict, you must immediately email the funder program office, which will trigger yet another amendment.
  • While looking for amendments, also look for a Q and A page on the funder website. Some funders will post questions received about the RFP, along with answers. Don’t however, get your hopes up, as the answers usually are something along the lines of, “Interesting question, refer to page 147 of the RFP.”
  • While we advise our clients to submit proposals a couple of days in advance of the deadline, there is no advantage in submitting a proposal more than about three days in advance. Otherwise, you might have try to “un-submit” the proposal if there is a late breaking amendment. Also, being first in line doesn’t help, as funders never release proposals to reviewers until the deadline passes.

A few months ago, we were writing a proposal for a for-profit client in a Northeaster state, which was seeking a Department of Homeland Security contract for facility hardening. There were ultimately seven amendments, each of which significantly changed the proposal response, and a couple of which came after the original deadline, meaning that we actually prepared three “final” proposals for this assignment. The punch line is that, ultimately, DHS cancelled the RFP process and decided not to make any grants!

In grant writing, it pays to heed the advice of “Oscar” in Robert Heinlein’s 1963 science fiction classic, Glory Road, which I’ll paraphrase as, “all bureaucracies consist of a Surprise Department, a Practical Joke Department, and a Fairy Godmother Department.” In grant writing, the Fairy Godmother Department is only open one day per year, so mostly you’re at the mercy of the Surprise and Practical Joke Departments.

Favorite odd-but-mandatory proposal forms: LA Slavery and New York Northern Ireland edition

Experienced grant writers know that all proposal instructions must be followed as precisely as possible (though they can also be contradictory—a problem we discovered in a recent Department of Education RFP). Perhaps because of that principle, funders (or their political masters) also get the chance to include absurd or bizarre forms with RFPs. Some of our favorites include ones from City of Los Angeles Departments, since the City requires that firms it contracts with, including nonprofits, certify that the organization wasn’t been involved in slavery. For those of you keeping track at home, slavery ended in the United States in 1865 and Seliger + Associates was founded in 1993.

Today was I working on behalf of a New York client and ran into the “Empire State After-School Program,” which is a fairly standard after school program not so different from the 21st Century Community Learning Centers program or many other, similar programs. But this one is issued by the state of New York, and, amid the pile of pretty typical required documents (like “Non-Collusive Bidding Certification Required by Section 139d of the State Finance Law (OCFS-2634)”) was one that caught my attention: “MacBride Fair Employment Principles in Northern Ireland (OCFS-2633).”

Northern Ireland?

I was curious enough to follow the link to the form and found that grantees for this program apparently must certify as to whether it has ever conducted business in Northern Ireland. If it has, these instructions apply, and the applicant:

Shall take lawful steps in good faith to conduct any business operations that it has in Northern Ireland in accordance with the MacBride Fair Employment Principles relating to non-discrimination in employment and freedom of workplace opportunity regarding such operations in Northern Ireland, and shall permit independent monitoring of its compliance with such principles.

I don’t know what discriminatory practices might be common in Northern Ireland. Nor do I know why New York State in particular is concerned with this tiny corner of the world. Out of curiosity, I checked the CIA World Factbook, and it says that Ireland’s entire population is a smidgen under five million, or about 60% the size of New York City’s alone.

Somewhere back there in the haze of New York political history must be some Irish-related controversy that lives on, to this day, in the form of a form that random nonprofits providing after-school services must include or risk being rejected as technically incorrect. Keep in mind that in the good old days of 1931, the Empire State Building was built in one year and 45 days. I’m pretty sure the developer did not have to fill out a Slavery or Northern Ireland form, which likely speedup up the process. Sometimes I see the more absurd aspects of grant writing and think about cost disease and how computers have paradoxically made grant writing worse.

Maybe reading is harder than I thought: On “The Comprehensive Family Planning and Reproductive Health Program”

We very occasionally pay attention to bidders conferences; usually, however, we usually avoid them for the reasons last discussed in “My first bidders conference, or, how I learned what I already knew.” Despite knowing that bidders conferences are mostly a waste of time, we’re sufficiently masochistic careful enough that we’ll occasionally look into one anyway.

New York State’s “Comprehensive Family Planning and Reproductive Health Program” bidders conference was a special example of silly because it literally consisted of the presenter reading from slides that regurgitated the RFP. As the “conference” went on, it became steadily more apparent that the conference would literally only consist of . . . repeating what’s in the RFP. This is as informative as it sounds.

After 20 minutes of listening to the presenter read, I gave up. I can read it myself. Still, as I shook my head at the seemingly pointless waste of time, my mind drifted back to some of my experiences teaching college students, and I have to wonder if the presenter read the RFP as a defensive strategy against inane questions that could easily be answered by the RFP. Something similar happens to me in class at times.

One recent example comes to mind. I had a student who seemed not to like to read much (note: this is a problem in English classes), and one day I handed out an essay assignment sheet with specific instructions on it. I told students to read it and let me know if they had questions. This student raised her hand and I had a conversation that went like this:

Student: “Can you just go over it in general?”
Me: “What’s confusing?”
Student: “I mean, can you just say in general what the assignment is about?”
Me: “That’s what the assignment sheet is for.”
Student: “I don’t understand. Can you go over it?”
Me: “What part confuses you?”
Student: “The entire thing.”
Me: “Which sentence is confusing to you?”
Student: “Can you just go over it in general?”

This was not a surrealist play and by the end of the exchange—I did not reproduce the whole exchange—I was somewhat confused, so I began reading each individual sentence and then checking in with the student. This was somewhat embarrassing for everyone in the class but I didn’t really know what else to do.

When I got to the end of the assignment sheet, the student agreed that it was in fact clear. I know enough about teaching not to ask the obvious question—”What was all this about?”—and yet I’ve had enough of those experiences to identify, just a little, with the people running the world’s boringest* bidders conferences.


* Not an actual word, but I think it fits here.