Category Archives: Grants

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

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

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

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

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

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

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

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

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

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

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

Generalized human and social services: ACF READY4Life and Fatherhood FIRE RFPs

Astute newsletter readers saw two useful Administration for Children and Families (ACF) Office of Family Assistance (OFA) RFPs with lots of money available (albeit with overly long names) in our last edition: Fatherhood – Family-focused, Interconnected, Resilient, and Essential (Fatherhood FIRE) and Relationships, Education, Advancement, and Development for Youth for Life (READY4Life). Both have grants to $1.5 million for family formation and resilience services. A phrase like “family formation and resilience services” should make smart nonprofit Executive Directors sit up and take notice, because we’ve seen fewer overt generalized human services grants over the past few years—the kind of grants that we sometimes call “walkin’ around money.

Smart organizations figure out that these kinds of grants can be used to fill in the cracks of an organization’s budget, because the project concepts that can be funded are broad. Also, in most cases, only a process evaluation (e.g., number of outreach contacts made, number of referrals, etc.) is feasible, since there’s usually no way to tract outcomes. In the ’90s and ’00s we saw more broad, general-purpose RFPs, but we’ve seen fewer since the Great Recession. The feds seem to have lost interest in many kinds of general-purpose grants and have instead been targeting particular services, like primary health care and job training.

Many organizations are already doing things like fatherhood and family development, but without calling their activities “fatherhood and family development.” Federally Qualified Health Centers (FQHCs), for example, often serve low-income patients who are impoverished by single parenthood, usually in a female-headed household. Nimble FQHCs should apply for READY4Life, Fatherhood FIRE, and similarly nebulous grant programs, since they can re-brand their existing Case Managers and Patient Navigators as “Family Support Coordinators” and “Parenting Specialists.” Obviously, the FQHC wouldn’t say as much in the proposal—that would be supplantation—but, in the real world, a lot of organizations keep their lights on and their clients happy using these strategies.

Organizations apart from FQHCs should be doing this too. Job training and homeless services providers, for example, often work with populations that need family reunification training, and the organizations are already often providing wraparound supportive services. Funders love synergistic proposals that say things like, “We’re going to do job training services for ex-offenders, and those ex-offenders will also be eligible for Fatherhood FIRE services in order to ensure that they remain in their children’s lives.”

Increased funding for generalized human services typically follows some kind of seismic societal shock. Seliger + Associates began in 1993, soon after the Rodney King verdict civil unrest, which was soon followed by the onset of mass school shootings with Columbine. Then came the Great Recession: the feds respond to social turmoil with huge new grant programs (21st Century Community Learning Centers was an example) and big budget increases for existing programs (like the 2009 Stimulus Bill). With the COVID-19 crisis, the cycle is repeating. Since March, three giant stimulus bills have been passed, with at least one more likely. The enormous civil unrest and protests unfolding after the recent police killing of George Floyd will likely lead to grant programs too; the feds’s objective is to get grants on the streets quickly to nonprofits, which act as a kind of buffer to politicians.

With growing “defund the police” sentiment in big, left-leaning cities, politicians are engaging in a sort of bidding war with proposed police budget cuts; politicians say some version of, “We want to redirect huge amounts of police budgets to solving the underlying problems that generate crime.” Translated, this means, “We plan to fund local nonprofits to conduct some kind of human services.”

Grant writing in another time of civil disturbances

Once again, I find myself writing grant proposals during a time of tragic civil disturbances across America.* My entire life and career have been shadowed by such events. I came of age in the 1960s, a time of extreme social unrest, both race-related—like the 1965 Watts Rebellion—as well as often violent anti-Vietnam protests. I went to my first civil rights march in Paducah, KY in 1965 (my older brother was working for the then-new Job Corps there) and participated in many anti-war marches while in college at the University of Minnesota. As I wrote about in my first GWC post in 2007, “They Say a Fella Never Forgets His First Grant Proposal,” I got my grant writing start working as a community organizer in North Minneapolis in 1972. I grew up in North Minneapolis, when it was a Jewish, trending Black, ghetto, and the community was devastated by what were then called “race riots” in 1967 and 1968. In 1972, my job was to try to get some local businesses going again, as North Minneapolis hadn’t recovered—and, in many ways, it still hasn’t recovered.

In 1992, the genesis of what ultimately became Seliger + Associates was born out of the ashes of the civil disturbances following the Rodney King verdict. I happened to be visiting friends in the Hollywood Hills when the disturbances began, and we could see the fire burning across South LA and Koreatown that night from their deck. Based on my experiences over the years, I assumed that huge amounts of federal grant funds would follow soon, and that it might be a good time to ditch my career as as city-slug community development director and try setting up a grant writing business instead. I did just that in 1993 and discovered that there was indeed a market for good grant writing consultants. The timing was also propitious because the incipient Internet allowed us to work for people across the country in a way that wasn’t possible before it.

Flash forward: in 2014, I wrote a post about about grant writing and the Ferguson, MO civil disturbances in which I noted that grant money follows major incidences of civil unrest. The government only has two real tools to use in this situation: the stick of yet more policing (the problems of which are readily observable in the news) or the carrot of grant funds to help the affected communities recover.

As I write this, civil unrest is unfolding from Minneapolis to NYC, LA, and much of the rest of America, following the obvious, videotaped murder of George Floyd.** These horrific images are juxtaposed with the inspiring images of the first manned SpaceX/NASA launch. It’s very troubling to realize that, while much has changed since I was a high school freshman in 1965, some things haven’t; then, I was listening to Barry McGuire’s huge hit single, “Eve of Destruction“: “You may leave here for four days in space, but when you return it’s the same old place.” The reference is to the Gemini 4 flight and civil rights marches/violence of the era. Feels like we’re poised on another Eve of Destruction.

Unlike Ferguson in 2014 and LA in 1992, today’s situation is more like the huge unrest that followed MLK’s assassination in 1968 in that it has radiated out to more than 40 cities and, after five nights of burning and looting, shows no sign of abating. This is unfolding after months of COVID-19 lockdowns, and those most harmed by both the virus and the lockdowns have been low-income communities of color. I’ve worked in and around these communities for over four decades: when the lockdowns began, I thought and discussed privately (but not in a post) that this could lead to great civil unrest. I wasn’t talking about the gun guys marching in front of state capitols, but rather what erupted last week in Minneapolis. While I couldn’t predict the spark, I suspected civil unrest would follow. Force millions of low-income workers to stay at home in overcrowded housing, while their jobs and incomes evaporate, and this outcome should not be surprising. If it wasn’t George Floyd, it would have been something else. I read James Baldwin’s The Fire Next Time when I was a teen and it rings true today: “God gave Noah the rainbow sign / No more water but fire next time.”

The combination of civil unrest and tens of thousands of small businesses closing in places like South Minneapolis and Flatbush in Brooklyn will be devastating for years and possibly decades to come. As noted in a recent New York Times article, “According to one recent poll, nearly 40 percent of adults living in cities have begun to consider moving to less populated areas because of the outbreak. In New York, where I live, roughly 5 percent of the population — or about 420,000 people — have already left.” For the near term, gentrification and densification of cities, big and small, is over.

Still, the twin scourges of COVID-19 and civil unrest will present great grant opportunities for nimble nonprofits, cities, and other public agencies. The three COVID-19 relief bills passed so far are raining over $2 trillion on the country, much in the form of grants, with a fourth bill likely to pass soon. We’ve been writing COVID-19 proposals furiously for two months and know that at least $2.4 million in COVID-related grants we’ve written has already been funded. The inevitable huge increase in available federal grant money, due to the civil unrest, will soon follow. If you run a nonprofit, city department, or school district, once you’re done mourning for George Floyd and recovered from the shock of COVID-19, be ready. The grant waves this time will likely center on primary health care, behavioral health services, workforce development, and economic development. It’s not inconceivable that we’ll eventually address the underlying pathologies that have bedeviled American history since before the country’s founding. But I’ve been hoping for that for decades and it remains elusive.


* For purposes of this post, I’m focusing on the negative aspects of what’s happening, not the legitimate underlying protests against police brutality. I’ll leave the details of those issues to others, while noting that police unions create systemic challenges around dealing with police misconduct; the Supreme Court’s doctrine of qualified immunity is the other challenge. The date stamps on both those links are from years ago; knowledge about these problems has circulated among intellectuals and policy nerds for years.

** On a personal note, I took my Golden Retriever to doggy day care Sunday morning, which I do most Sundays. The store, Posh Pet, is just off the part of Melrose Avenue in West Hollywood that was trashed Saturday night. When I got there, I found this sign in the window: “We have dogs here. Please don’t break window.” The glass door was smashed and the business completely looted. No idea what happened to the dogs being boarded. This small business was barely hanging on, due to COVID-19. Now, it may never reopen.

Less obvious things that impact human services during the coronavirus pandemic

The news about coronavirus focuses rightly on life and death and the struggles of hospitals, as well the need for social distancing and the suspensions of large gatherings. Emergency measures that last for a few weeks are one thing, but it looks like this crisis may continue for several months. While the media is generally doing a good job of crisis coverage, some aspects of particular interest to nonprofit human services providers are being narrowly covered at best.

For example, arrests by the LAPD are dropping, and many court systems are deferring or dismissing non-felony cases, since no one wants coronavirus to rip through jails. It’s hard to say what lowered policing and low-level case dismissal means: maybe many arrests were bogus in the first place. But maybe they weren’t, and we’re likely going to see substantially increased crime as people adjust to this new normal—most big city cops aren’t arresting people, even for such fairly serious crimes as burglary and car break-ins. It’s also possible that petty crime—and even crime in general—will decline because would-be criminals are at home and either don’t want to get coronavirus themselves, or they know most people are holed up at home, and many of those holed up at home are armed. It’s beyond the purview of our knowledge and subject matter to discuss this in detail, but there’s also a lively debate about whether most crime is premeditated versus simply persons seeing what they perceive as opportunity and then acting on it.

Some incarcerated persons are already being released early; released arrestees and, more importantly, recently released prisoners need something productive to do and to earn legitimate income—which usually means case-managed job training and placement of some kind. We’ve written many funded proposals for services for ex-offenders and, even in good times, this is not an easy population to work with. The unemployment rate is likely 10% and may spike as high as 20% in the coming months, further complicating matters. In the short term, however, there’ll be huge need, and likely lots of grant money available, to provide these services. Training and placement, alway challenging, will be hard, given social distancing, but some nonprofits have to try, perhaps with sufficient social distancing measure and/or tele-case management.

Another issue: thousands of 12-Step Program meetings, like Alcoholics Anonymous, are being cancelled—and these programs are based mostly on in-person peer support. Behavioral health provides will have to suspend in-person individual and group sessions, leaving millions more with SUD/OUD and/or severe and persistent mental illness (SPMI) more or less on their own. Add the incredible stressors of job/income loss, stay-at-home orders, and the like to addiction and mental health issues, and a huge human toll is likely. We’ve seen estimates that 10% of the US population has mental health or substance abuse challenges that are mitigated by in-person support. Most people don’t get the same effects from digital communications tools that we do from in-person interaction. Still, this is an opportunity for nimble nonprofits to seek foundation and government grants to establish or scale-up tele-behavioral health services.

Lots of people have realized that shuttered movie theaters may never recover; fewer people are thinking openly about what we ought to be doing with the most vulnerable persons who are facing serious disruptions, on top of the obvious coronavirus disruptions.

Community foundations and grants that are more work than they’re worth

We get calls from some (inexperienced) potential clients who want to pursue “community foundation” grants, which are usually small grants that range up to $5,000 or $10,000, but we almost always tell them the same thing: those grants aren’t worth chasing. We’ve mentioned that, in grant writing, zeroes are cheap, and many very large grants aren’t much harder to get, and to manage, than smaller grants.

Something unusual, however, just happened: We got a phone call from a community foundation CEO who is unhappy because he’s finding small grants harder and harder to give away. It seems that this community foundation offers free grant writing training to local nonprofit leaders in hopes of helping them understand how to write proposals, but the nonprofit executive directors still can’t be bothered to fill out the foundation’s relatively simple applications for the small grants it offers. The foundation is trying to get the local nonprofits to seek funding from it, but they won’t, because of the problems I mention in the first paragraph. While we love work, there’s nothing we could do for this foundation to solve this problem—we said him that the foundation should make the grants larger and they’ll get more applications. Alternatively, just give the money away without an application.

We also got a recent call from a client who is now turning down these kinds of smaller grants. Why would an organization turn down money? Because, the client said, by the time the she applies, deals with the bureaucracy, gets the money, and accounts for the money, there is little or no real money left to provide services—it’s all gone into administration. Dedicating management resources for $500,000 or million-dollar grants makes sense. Dedicating management resources for $5,000 grants doesn’t.*

Community foundations that want to make an impact are better off just sending the check to the nonprofits they already like without requiring an application. Or, they could invite nonprofits to submit applications they’re already submitting. For example, we recently worked on a SAMHSA Strategic Prevention Framework – Partnerships for Success (SPF-PFS) application; a community foundation interested in opioid use disorder (OUD) prevention and treatment could say to a local nonprofit, “If you’re already applying for a grant and send it to us, we’ll review it too, just using our own criteria.” Emailing a copy of an existing grant is easy—it would be something like the college Common Application in college admissions, but for grants. As far as I can remember, we’ve never seen a foundation do this.

I feel bad for community foundations that are trying to give away money unsuccessfully—but there is (rarely) such thing as a free lunch, and nonprofits know that friction costs are real.


* As Isaac relates in the very first post we put up, back in 2007, the first grant proposal he wrote in 1972 was for $5,000. That made sense then, as $5K was real money in 1972, but it’s not any more.

Don’t split target areas, but some programs, like HRSA’s Rural Health Network Development (RHND) Program, encourage cherry picking

In developing a grant proposal, one of the first issues is choosing the target area (or area of focus); the needs assessment is a key component of most grant proposals—but you can’t write the needs assessment without defining the target area. Without a target area, it’s not possible to craft data into the logic argument at is at the center of all needs assessments.

To make the needs assessment as tight and compelling as possible, we recommend that the target area be contiguous, if at all possible. Still, there are times when it is a good idea to split target areas—or it’s even required by the RFP.

Some federal programs, like YouthBuild, have highly structured, specific data requirements for such items as poverty level, high school graduation rate, youth unemployment rates, etc., with minimum thresholds for getting a certain number of points. Programs like YouthBuild mean that cherry picking zip codes or Census tracts can lead to a higher threshold score.

Many federal grant programs are aimed at “rural” target areas, although different federal agencies may use different definitions of what constitutes “rural”—or they provide little guidance as to what “rural” means. For example, HRSA just issued the FY ’20 NOFOs (Notice of Funding Opportunities—HRSA-speak for RFP) for the Rural Health Network Development Planning Program and the Rural Health Network Development Program.

Applicants for RHNDP and RHND must be a “Rural Health Network Development Program.” But, “If the applicant organization’s headquarters are located in a metropolitan or urban county, that also serves or has branches in a non-metropolitan or rural county, the applicant organization is not eligible solely because of the rural areas they serve, and must meet all other eligibility requirements.” Say what? And, applicants must also use the HRSA Tool to determine rural eligibility, based on “county or street address.” This being a HRSA tool, what HRSA thinks is rural may not match what anybody living there thinks. Residents of what has historically been a farm-trade small town might be surprised to learn that HRSA thinks they’re city folks, because the county seat population is slightly above a certain threshold, or expanding ex-urban development has been close enough to skew datasets from rural to nominally suburban or even urban.

Thus, while a contiguous target area is preferred, for NHNDP and RHND, you may find yourself in the data orchard picking cherries.

In most other cases, always try to avoid describing a target composed of the Towering Oaks neighborhood on the west side of Owatonna and the Scrubby Pines neighborhood on the east side, separated by the newly gentrified downtown in between. If you have a split target area, the needs assessment is going to be unnecessarily complex and may confuse the grant reviewers. You’ll find yourself writing something like, “the 2017 flood devastated the west side, which is very low-income community of color, while the Twinkie factory has brought new jobs to the east side, which is a white, working class neighborhood.” The data tables will be hard to structure and even harder to summarize in a way that makes it seem like the end of the world (always the goal in writing needs assessments).

Try to choose target area boundaries that conform to Census designations (e.g., Census tracts, Zip Codes, cities, etc.). Avoid target area boundaries like a school district enrollment area or a health district, which generally don’t conform to Census and other common data sets.

Washington Post’s story on rural health care ignores Federally Qualified Health Centers (FQHCs) — huh?

Eli Saslow recently wrote a 3,500-word Washington Post story about rural healthcare in “Urgent needs from head to toe’: This clinic had two days to fix a lifetime of needs.” Although it reads like a dispatch from Doctors Without Borders in Botswana, Saslow is describing rural Meigs County TN. Rural America certainly faces significant unmet healthcare needs, but this piece has a strange omission: it doesn’t mention Federally Qualified Health Centers (FQHCs).

The Tennessee Primary Care Association reports over 30 Federally Qualified Health Centers (FQHCs) operating over 200 health clinics in the state, most in rural areas—including at least four in or near Meigs County! FQHCs are nonprofits that receive HRSA Section 330 grants to provide integrated primary care, dental care, and behavioral health services to low-income and uninsured patients. FQHCs also accept Medicaid and, in rural areas, are usually the main primary care providers, along with ERs.

Federal law requires FQHCs to provide services under a sliding-fee scale, with a nominal charge for very-low-income patients—in theory, at least, FQHCs never turn patients away due to lack of ability to pay. Similarly, federal law requires ERs to treat everyone, regardless of income and/or insurance status. Unlike ERs, however, FQHCs provide a “medical home” for patients. There are over 1,400 FQHCs, with thousands of sites, both fixed and mobile, to better reach isolated rural areas like Meigs County. We should know—we’ve written dozens of funded HRSA grants for FQHCs, including many serving rural areas like Meigs County.

The story’s hero is Rural Area Medical (RAM), a nonprofit that appears to set up temporary clinics under the free clinic model. Free clinics emerged from the runaway youth health crisis of the late 60s, starting in the Summer of Love in San Francisco—I was on the board of a free clinic over 40 years ago and understand the model well. While there are still over 1,400 official free clinic sites, free clinics largely depend on volunteer medical staff, may not accept Medicaid, and have insecure funding because they rely on donations (often from their volunteers) to keep the lights on. To operate, a free clinic must necessarily devote much of its resources away from direct services to maintaining volunteers and fundraising, like any nonprofit that depends on volunteer labor (think Habitat for Humanity).

Unlike FQHCs, free clinics patients don’t have a designated primary care provider (PCP), since a given doc or NP might be volunteering or not on a given day—like an ER, free clinic patients lack a true medical home. Free clinics aren’t generally eligible to participate in the federally subsidized 340B Discount Pharmacy Program, so patients don’t have access to long-term, low-cost medications. Free clinics, while once the only source of healthcare for many uninsured, have now mostly been overtaken by FQHCs, much as the days of the independent tutor ended with the coming of public schools. We’ve worked for a few free clinics over the years, and most were struggling to stay open and provided erratic services. Their executive directors could feel which way the wind is blowing and consequently many were trying trying to become FQHCs.

I wonder: has RAM applied to become an FQHC and open a permanent site in Meigs County? I don’t know anything about Meigs County, and it’s possible that the local FQHCs are incompetent or poorly run and could use some new competitors. HRSA just had a New Access Points (NAP) competition, with over $200 million to found and fund new sites. If the the healthcare situation is dire in Meigs County, applying for NAP grant makes much more sense than setting up shop for a weekend. Does RAM refer patients to local FQHCs? That may be a more efficacious long-term solution than the superman approach of flying in, saving the day, and flying out (imagine if education worked the same way, with itinerant teachers stopping by to give a lecture on geometry one day, Shakespeare’s sonnets the next, and the gall bladder the day after).

The original story is great as human interest, but it doesn’t go into root causes. Some consulting organization created the “Five Whys” strategy or methodology, which holds that, for any given problem, it’s often not useful to look at a single moment or cause of failure or inadequacy. Rather, systems enable failure, and for any given failure, it’s necessary to look deeper than the immediate event. Some of the other underlying problems in this story include the American Medical Association (AMA), which controls med school slots, and the individual medical specialty associations, which control residency slots. The U.S. has been training too few doctors and doing an inadequate job getting those doctors into residency for decades. Detail on this subject is too specific for this piece, but Ezekiel Emanuel has a good article on the subject; med school needs to be integrated with undergrad and needs a year lopped off it. The way medical training works right now is too expensive and too long, creating physician shortages—especially in the places that need physicians most. The supply-demand mismatch raises the costs of physician services and mean that physicians charge more for services than they otherwise would.

Rural areas have also faced decades of economic headwinds, with young adults moving to job centers, leaving an aging-in-place population that needs many support services; declining tax base from manufacturing leaving for emerging countries; the opioid epidemic; and so on. While I wouldn’t expect Saslow to fully cover such factors, context is missing and at least a passing reference to FQHCs would make sense.

Another piece of the evaluation puzzle: Why do experiments make people unhappy?

The more time you spend around grants, grant writing, nonprofits, public agencies, and funders, the more apparent it becomes that the “evaluation” section of most proposals is only barely separate in genre from mythology and folktales, yet most grant RFPs include requests for evaluations that are, if not outright bogus, then at least improbable—they’re not going to happen in the real world. We’ve written quite a bit on this subject, for two reasons: one is my own intellectual curiosity, but the second is for clients who worry that funders want a real-deal, full-on, intellectually and epistemologically rigorous evaluation (hint: they don’t).

That’s the wind-up to “Why Do Experiments Make People Uneasy?“, Alex Tabarrok’s post on a paper about how “Meyer et al. show in a series of 16 tests that unease with experiments is replicable and general.” Tabarrok calls the paper “important and sad,” and I agree, but the paper also reveals an important (and previously implicit) point about evaluation proposal sections for nonprofit and public agencies: funders don’t care about real evaluations because a real evaluation will probably make the applicant, the funder, and the general public uneasy. Not only do they make people uneasy, but most people don’t even understand how a real evaluation works in a human-services organization, how to collect data, what a randomized controlled trial is, and so on.

There’s an analogous situation in medicine; I’ve spent a lot of time around doctors who are friends, and I’d love to tell some specific stories,* but I’ll say that while everyone is nominally in favor of “evidence-based medicine” as an abstract idea, most of those who superficially favor it don’t really understand what it means, how to do it, or how to make major changes based on evidence. It’s often an empty buzzword, like “best practices” or “patient-centered care.”

In many nonprofit and public agencies, evaluations and effectiveness are the same: everyone putatively believes in them, but almost no one understands them or wants real evaluations conducted. Plus, beyond that epistemic problem, even if evaluations are effective in a given circumstance (they’re usually not), they don’t necessarily transfer. If you’re curious about why, Experimental Conversations: Perspectives on Randomized Trials in Development Economics is a good place to start—and this is the book least likely to be read, out of all the books I’ve ever recommended here. Normal people like reading 50 Shades of Grey and The Name of the Rose, not Experimental Conversations.

In the meantime, some funders have gotten word about RCTs. For example, the Department of Justice’s (DOJ) Bureau of Justice Assistance’s (BJA) Second Chance Act RFPs have bonus points in them for RCTs. I’ll be astounded if more than a handful of applicants even attempt a real RCT—for one thing, there’s not enough money available to conduct a rigorous RCT, which typically requires paying the control group to follow up for long-term tracking. Whoever put the RCT in this RFP probably wasn’t thinking about that real-world issue.

It’s easy to imagine a world in which donors and funders demand real, true, and rigorous evaluations. But they don’t. Donors mostly want to feel warm fuzzies and the status that comes from being fawned over—and I approve those things too, by the way, as they make the world go round. Government funders mostly want to make congress feel good, while cultivating an aura of sanctity and kindness. The number of funders who will make nonprofit funding contingent on true evaluations is small, and the number willing to pay for true evaluations is smaller still. And that’s why we get the system we get. The mistake some nonprofits make is thinking that the evaluation sections of proposals are for real. They’re not. They’re almost pure proposal world.


* The stories are juicy and also not flattering to some of the residency and department heads involved.

The weakness of the Community Development Financial Institutions (CDFI) Program, in a paragraph

We’re fans of the Community Development Financial Institutions Program (CDFI), which usually has tens (or hundreds) of millions of dollars available annually “to promote economic revitalization and community development” through investment in local startups and businesses. The CDFI Program—notice the capital “P”—is separate from the CDFIs themselves, which are local organizations that offer loans and investments in local companies and are certified as CDFIs by the Department of the Treasury.

I was thinking about CDFIs when I read “How the 22-year-old founders of Brex built a billion-dollar business in less than 2 years,” which is an interesting story in its own right but also says this:

As founders themselves, Dubugras and Franceschi were hyper-aware of a huge problem entrepreneurs face: access to credit. Big banks see small businesses as a risk they aren’t willing to take, so founders are often left at a dead-end. Dubugras and Franceschi not only had a big network of startup entrepreneurs in their Rolodex, but they had the fintech acumen necessary to build a credit card business designed specifically for founders.

Those “Big banks” are exactly who CDFIs are supposed to compete with. Yet the CDFI program has been operating since 1994 and was a much-ballyhooed part of President Clinton’s domestic policy agenda. Over the years, the CDFI Program has largely faded from view, although we still write CDFI proposals every couple years. Still, access to credit remains a massive problem—and one that the Brex founders have tackled, even though CDFIs were (and are) well-placed to do exactly what Brex did.

It’s distressing that, even after decades of CDFI, high-quality entrepreneurs are still struggling to get capital out of existing financial institutions. If I were a CDFI manager in charge of the next program application, I would both cite this article and describe how my CDFI will avoid the traditional Catch-22 of banking and loans: the only entities that can get the loan are the ones that don’t really need it. Venture capital is one way to break that Catch-22. But there ought to be others.

CDFIs have potential. The “weakness” in the title of this post is not meant to be a sign of just another person on the Internet, calling names. It’s meant to be addressed by CDFIs themselves in the next funding round.

I’ve never heard of a startup applying for funding from a CDFI. Doesn’t mean it hasn’t happened, but it is notable. If you know of any that have, please leave a not in the comments.

In addition, it’s notable that most corporate credit cards are still… not very friendly, to speak euphemistically. We know from experience. Maybe we’ll be applying for a Brex card in the near future.