Search Results for: Grants.gov

Posted on by — 1 Comment

You know you’re a grant writer if a Health Resources and Services Administration (HRSA) Service Area Competition (SAC) deadline vexes you

You know you’re a grant writer if… You’re reading the Health Resources and Services Administration’s (HRSA) Service Area Competition (SAC) and discover that the deadline is July 6.

You’re frustrated because Monday, July 6 is a holiday for most people: the Fourth of July is Saturday, so the “holiday” part is the Monday after, which means that you won’t get much tech support if you need it on that Monday. You probably won’t get any tech support on Friday, July 3, either, since everyone in the federal government will probably have left—most of the Feds count that Friday as the holiday this year.

The real deadline is probably closer to July 2, chiefly because whatever genius at HRSA picked this deadline probably didn’t realize it was a holiday weekend, or simply decided to play a cruel trick on applicants. There are two possible reasons for this snafu: incompetence or malice. Neither portrays HRSA in a positive light. Oh, and applicants for this program are “Section 330” nonprofit community health centers, which are perhaps not the best targets for a HRSA practical joke, especially given how tremendously complex and difficult the applications are.

You know you’re a grant writer if… the same SAC RFP further irritates you because you have to submit a preliminary application using Grants.gov for a June 23 deadline, then submit the full application using HRSA’s Electronic Hand Books (EHB) system with a deadline of July 6 July 2. In other words, you have to learn yet another esoteric electronic system, although one that’s at least somewhat easier than Grants.gov.

You know you’re a grant writer if… you find Grants.gov’s failures and quirks amusing, causing you to write about them with some frequency.

You know you’re a grant writer if… the budget you receive from your client has no relationship to the narrative you’ve written, based on what the client told you in the first place. Actually, the budget has nothing to do with little if anything to do with anything whatsoever.

You know you’re a grant writer if… you’re the only person in America working on a holiday, other than cops and escorts.

You know you’re a grant writer if… you don’t even realize that tomorrow is a holiday—Memorial Day—and have to be told to hold the Seliger Funding Report for another day.

You know you’re a grant writer if… you’re outraged when you find that a deadline is on the holiday you hadn’t realized was there (see: first paragraph, above).

You know you’re a grant writer if… you’re inclined to write lists regarding when you know you’re a grant writer, and you actually think they’re amusing.

Posted on by — 1 Comment

The Department of Housing and Urban Development’s (HUD) Neighborhood Stabilization Program (NSP) Appears at Last

Subscribers to the Seliger Funding Report saw that the Neighborhood Stabilization Program (NSP) is this week’s featured grant. The program is significant and worth examining for a few reasons, including the massive amount of money available (nearly $2 billion) and how it illustrates some of the problems with disseminating and spending stimulus money in a timely manner.

The idea behind the stimulus funding is that it’s supposed to happen quickly. Last December, Isaac wrote a post on the subject:

Our client has been going to endless meetings to discuss the NSP program and is still waiting around for the amended action plans to be approved. […]

This sad tale of woe does not make me optimistic about the really big stimulus programs that will emerge from Congress shortly. While it will be Fat City for grant writers and lots of grants will be available for frisky nonprofit and public agencies, don’t expect the funds to fix many problems.

It’s now six months later, and the RFP has finally hit the street. The deadline is July 17, which is sweet for the agencies applying but not so good on the timeliness front. Once awards are made, contracts are signed, and programs begin operating in earnest, it could well be December again. Isaac also quoted a Wall Street Journal article from December that’s as timely today as it was then, which should demonstrate the sense of urgency emanating from HUD.

Another point: HUD has apparently abandoned Grants.gov. You won’t find the actual RFP on Grants.gov—you’ll only find a link to hud.gov/recovery. Even then, the RFP is still difficult to find because you’ll find a giant scrolling banner, a link to a press release, and a news story about NSP, which is why we always include links, like the the one in the first paragraph of this post, that go straight to the RFP. In addition, HUD will only accept paper submissions:

Deadline for Receipt of Application: July 17, 2009. Applications must be received via paper submission to the Robert C. Weaver HUD Headquarters building by 5:00 p.m. Eastern Daylight Time. […]

Timely submission shall be evidenced via a delivery service receipt or a postal receipt with date and time stamp indicating that the application was delivered to a carrier service at least 48 hours prior to the application deadline…

Those of you with a sense of history and irony will find this amusing because was among the first (if not the first) agencies to require Grants.gov submissions. That HUD won’t even accept them anymore might tell you something about the Grants.gov problems we’ve discussed extensively.

Finally, this application is an example of HUD going both ways with funding distribution: some NSP funds are being passed through to states and counties via block grant, as described in Getting Your Piece of the Infrastructure Pie: A How-To Guide for the Perplexed, while this program notice says that “NSP2 funds will be awarded through competitions whose eligible applicants include states, units of general local government, nonprofits, and consortia of nonprofits. Any applicant may apply with a for-profit entity as its partner.” Sounds good to us!

Posted on by — 3 Comments

Professional Grant Writer At Work: Don’t Try Writing A Transportation Electrification Proposal At Home

Seliger + Associates was recently hired to edit a proposal for the charmingly titled U.S. Department of Energy National Energy and Technology Laboratory Recovery Act-Transportation Electrification (NETLRATE)* program. We edit proposals all the time; the unusual part of this assignment is our client, which is a successful tech company with lots of engineer types instead of the human service folks who typically hire us. The CEO told me that his company has experience in submitting business proposals to tech and manufacturing companies and would have no problem writing the proposal. They just wanted us to review it, but the resulting fiasco demonstrates why our client would have been much better served to simply hire us to write the entire proposal, even though we know little about electric vehicles (as I discussed in No Experience, No Problem: Why Writing a Department of Energy (DOE) Proposal Is Not Hard For A Good Grant Writer). But, as with the advice Wavy Gravy gave at Woodstock about watching out for the brown acid, “it’s your trip.”

A week or two went by, with the Seliger + Associates team using our secret proposal production machine to extrude applications. The deadline for our DOE client to email his draft came and went. Two days later, and within a week of the deadline, the draft appeared in my inbox, along with the 41-page, single-spaced Funding Opportunity Announcement (FOA). The email said we should look at page 33 of the FOA, which our client used as a guide to prepare the draft. I looked and found the ever-popular “review criteria.” Here is a snippet (it actually goes on for two pages):

Evaluation Criteria for Area of Interest 1, 2, and 3

Criterion 1: Technical Approach and Project Management Weight: 40%
• Responsiveness and relevance to the programmatic research goals and requirements identified in this announcement for this area of interest, including rationale for the vehicle and/or infrastructure design
• Demonstrated knowledge and understanding of vehicle design and manufacturing, related past and current work and how the proposed effort builds on or expands from these prior efforts to ensure a production-intent design, i.e., their adaptation of and application to specific vehicle propulsion systems and platforms
• Degree and source of the identified risk in demonstrating the proposed technology, including definition of potential technology deficiencies along with proposed solutions to mitigate the risk;
• Innovativeness of the proposed technology

I immediately knew that our client, no matter how smart and experienced a businessperson he is, had fallen into The Danger Zone of Common RFP Traps I wrote about last year. RFPs often include convoluted criteria that unnamed “reviewers” will supposedly use to score the proposal, which are often separate from the instructions for the proposal itself.

The problem is that such criteria are invariably hidden somewhere in the bowels of the RFP and may or may not be referenced in the RFP completion instructions. I did what I always do to find the instructions and searched for “pages” and “page,” and uncovered detailed instructions on how to construct the NETLRATE proposal on page 22 of the FOA. Here is a nugget from the four pages of instructions:

The project narrative must include:

• Project Objectives: This section should provide a clear, concise statement of the specific objectives/aims of the proposed project.

• Merit Review Criterion Discussion: The section should be formatted to address each of the merit review criterion and sub-criterion listed in Part V.A. Provide sufficient information so that reviewers will be able to evaluate the application in accordance with these merit review criteria. DOE WILL EVALUATE AND CONSIDER ONLY THOSE APPLICATIONS THAT ADDRESS SEPARATELY EACH OF THE MERIT REVIEW CRITERION AND SUB-CRITERION.

• Relevance and Outcomes/Impacts: This section should explain the relevance of the effort to the objectives in the program announcement and the expected outcomes and/or impacts.

The second bullet point references the “criterion discussion,”** where our client should have placed his 15-page, single-spaced narrative. He did not realize that there were instructions, so this would have been hard to do. But his draft included an abstract, the instructions for which are also on page 22. This means he must have seen the instructions without fully realizing what they were.

That was his first major problem. The second was the draft itself, which was filled with the kind of self-congratulatory public relations happy talk that one finds in news releases and brochures. While coherent and well written, it wasn’t proposalese. Rather, it reiterated the “a delicious lunch was served” formulations that every freshman journalism student learns not to write. And the proposal did not follow the pattern of the four criteria pages and 40 or so bullet points. The response was technically incorrect and would probably not be evaluated, per the second bullet point in the above FOA quote.

Within two minutes of opening the file, I realized that our client had misunderstood the FOA and had written a marketing piece, not a proposal. Since we don’t hide from our clients, I called our contact and gave him the bad news that there was no point in having us edit his draft, as it was formatted wrong and written like a press release. He took it well and didn’t try to shoot the messenger, which is a not uncommon reaction to bad news. As Clint Eastwood’s “Dirty Harry” Callahan says in Magnum Force, “A man’s got to know his limitations,” and our contact now does.

Instead of wasting our time and his money on pointless editing, I rewrote the Abstract to reflect the instructions along with the ever popular “5 Ws and the H” and produced a detailed outline of the proposal with about a dozen Word paragraph styles*** following the pattern of the completion instructions. I also wrote lots of connector phrases and left assorted blanks for him to fill in, which is a paint by numbers approach to grant writing (this reference shows you how old I am).

Due to other writing commitments caused by our old friend the Stimulus Bill, we couldn’t spend any more time on this project, no matter how much our client was willing to pay, as we never accept assignments we can’t complete. With a $16 million grant on the line, it would have been much more cost effective for our client to have hired us to write the entire proposal in the first place. You may have noticed the small text that scrolls at the bottom of TV ads showcasing cars like the new 2011 FiCrysler Electric Eel roadster tearing across the desert at at 150 MPH, stating “Professional driver on closed course, do not attempt.” When it comes to grant writing, spend your time working on things you know how to do and hire a pro.

* This acronym is not actually used in the FOA. I just wanted to see what it would look like. Let’s try pronouncing it: “nettlerate?” I would have changed the name to National Action to Make America Special through Transportation Electricfication (NAMASTE). Maybe I’ve spent too much time watching Lost or perhaps I just need a calming Sanskrit word after too much fevered Stimulus Bill grant writing.

** Obviously no English majors were involved in the production of this FOA, as I believe the work they were looking for is “criteria,” when referring to “criterion” in the plural, although saying “criterion” makes me feel vaguely intellectual.

ibm-1-small-3*** While the draft proposal was written in Word, no paragraph styles were used. Instead, he used the default “normal” style for everything, along with tab stops. This proposal looked like it had been typed by the curvy secretary, Joan Hollway, on my favorite TV program, Mad Men, using an IBM Selectric typewriter. We have a Selectric III (distinguished from the Selectric II by the spacey orange backlight on the tab bar). We rescued this remarkable example of industrial design 15 years ago, and it still performs flawlessly when called upon every couple of months to complete a paper form. It gets serviced every three years. We’ll be able to keep it until the last typewriter repairman dies, at which point we will use it as a boat anchor, since it weighs about 50 pounds. Incidentally, you can get a similar feel on some modern keyboards, like the IBM Model M / Unicomp Customizer.

Posted on by — 1 Comment

Fake Requests for Proposals (RFP) Notices Gain Popularity

When I was a kid, Isaac liked to quote the famous line from Ian Fleming’s James Bond book, Goldfinger: “The first time is happenstance. The second time is coincidence. The third time is enemy action” (that’s how I remember it, anyway, and I don’t have a copy of Goldfinger handy to check the quote). Actually, Isaac still says that not infrequently, and I’m going to appropriate it for this post, since I’m noticing a pernicious trend in the form of fake grant announcements, or announcements of announcements, in the Federal Register.

We discussed this particular irritating brand of federal idiocy in “A Primer on False Notes, Close Reading, and The Economic Development Administration’s (EDA) American Recovery and Reinvestment Act (ARRA) Program, or, How to Seize the Money in 42 Easy Steps:”

There’s also another other curious thing about th[e] March 5 announcement: it was an announcement of an announcement: “Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA.” This is like sending an announcement of a forthcoming invitation to a party—why not simply make the announcement, especially since the two followed each other within days? The situation could be fundamentally irrational, or there could be some unknown statutory requirement hidden in the legislative language, or someone at the EDA could have simply been tipsy while entering Grants.gov information.

Non-RFP RFPs, or non-announcement announcements, seem to be becoming more popular, like the outbreak of swine flu. Reading Grant Writing Confidential will help immunize you from this malady, but not from the itching, sweating, and swearing it might cause. For another example of it, check out the Solicitation for Proposals for the Provision of Civil Legal Services, which says: “The Request for Proposals (RFP) will be available April 10, 2009.” But April 10 has come and gone, and as far as I can tell a genuine RFP still hasn’t arrived. Now we’ve passed happenstance and entered the land of circumstance.

But the latest iteration of my favorite program to pick on, the Assistance to Firefighters Grants Program (AFG), includes this in its first full paragraph on page two:

The American Recovery and Reinvestment Act of 2009 provided $210 million in funding to DHS to construct new fire stations or modify existing fire stations. That funding opportunity will be announced in the near future and will NOT be part of this offering. Under the funding opportunity presented in this guidance, the AFG will only fund projects that do not alter the footprint or the profile of an existing structure. Projects for modifications that involve altering the footprint or the profile of an existing structure or projects that involve construction of new facilities will fall under a different funding opportunity.

(See some earlier posts on the AFG here and here.)

As Goldfinger would say, this is now enemy action. I wouldn’t be surprised if phantom announcements become more common as the kinds of deadlines buried somewhere in the Stimulus Bill American Recovery and Relief Act approach federal agencies like a swarm of swine flu virus particles from a gigantic congressional sneeze.

Posted on by — 2 Comments

No More Ball of Confusion: The Reality of the Grant Making Process is Really Simple and I’m the Guy to Explain It to You

  • In the April 20, 2009 Wall Street Journal, Elizabeth Williamson wrote “Stimulus Confusion Frustrates Business,” in which she states “Confusion over how to go after money allocated to various stimulus programs appears to be clouding corporate efforts to plan ahead . . .”
  • In the April 12, 2009 New York Times, Kirk Johnson wrote “Waving a Hand, Trying to Be Noticed in the Stimulus Rush,” which concerns a nonprofit group stumbling around looking behind the refrigerator looking for stimulus funds like our faithful Golden Retriever, Odette, sniffing after the scent of the salami she was tossed yesterday, and thinking, “it’s just got be here somewhere.” Kirk states, “Whether the stimulus even has a place for the ideas [the nonprofit] is pursuing is not clear.” Both the reporter and the nonprofit smell the grant salami, but can’t quite find it, while Odette eventually gives up and rolls on her back.

Sense a trend? I could cite a dozen other similar stories in which talented reporters interview presumably bright individuals, none of whom find the Stimulus Bill salami, but you get the idea: no one in the media is writing “how” stories about the ways federal funds are distributed. Instead, endless “who,” “what,” “where” and “when” articles are published, leaving readers to assume the whole process, is, as the Temptations sang when I was in high school in 1968, just a Ball of Confusion. To quote:

Evolution, revolution, gun control, sound of soul.
Shooting rockets to the moon, kids growing up too soon.
Politicians say more taxes will solve everything.
And the band played on.
So, round and around and around we go.
Where the world’s headed, nobody knows.
Oh, great googalooga, can’t you hear me talking to you.
Just a ball of confusion.

Every time I see a “ball of confusion” story about the Stimulus Bill, I write the same note to the reporter . . . “call me and in 15 minutes, I will explain how federal funding actually is distributed.” Few call, perpetuating the “ball of confusion” story line. Like Tiny Mills, my favorite professional wrestler when I was a kid growing up in the late ’50s in Minneapolis, used to say when being interviewed by announcer Marty O’Neil, “I’m all burned up, Marty, I’m all burned up.” Since I’m all burned up about the slipshod Stimulus Bill reporting, here is the shorthand version of the federal funding process (and even this is a slightly simplified version):

  • Imagine Barney Frank (if you are a Democrat) or John Boehner (if you are a Republican) waking up one morning with a bright idea to solve some real or imagined problem in American by taking money from Peter to help Paul.*
  • The bright idea is turned into a bill, which both houses of Congress pass and the President signs.
  • Funding authorization for the newly minted program is included in a budget authorization bill. In some cases, the legislation creating the program and funding are in the same bill. The recently passed ARRA (“Stimulus Bill”) both creates new programs with funds authorized for the new programs and authorizes additional funding for existing programs. An example of the first case is the Department of Energy’s Smart Grid Investment Grant (SGIG) Program, which was originally created in 2007 but substantially modified with additional funding in the ARRA. An example of the second case is the Department of the Treasury’s Community Development Financial Institutions (CDFI) Program, which received an extra $100 million under the ARRA. A new NOFA was just issued with a deadline of May 27.
  • The new program is assigned to a Federal agency, which in turns assigns existing or new staff as Program Officers for the program.
  • Along with the requisite donut eating and mindless meetings, draft regulations are written and passed among Beltway types (e.g., legislation staff, “evil” lobbyists, interest groups, etc.) for informal review and comment. After the draft regulations are made as obtuse as possible, they are published in the Federal Register for public comment, usually for 30 days.
  • Final regulations are then published, usually featuring detailed explanations of why all the public comments are stupid and pointless, meaning the final regs are generally about the same as the draft regs. This is because interested parties have already taken their shots during the informal review process and Program Officers don’t care about what folks in Dubuque think anyway. It may take a federal agency anywhere from 30 days to 180 days to publish draft regs, and the review comment period is usually 30 days. The final regs will usually appear about 30 – 60 days later. The SGIG Program mentioned above is still in the informal regulatory review stage. A client sent us the draft regs, and they are a mess (the reasons why would be a post in itself). The FOA is being drafted simultaneously with the regs to speed up the process and the FOA is supposed to be published in June.
  • After the program regs are finalized, there are two possibilities, as follows:
    • (1) If the program is a federal pass-through to the states, the money is made available for the states to distribute, using an existing or new system, and based on some formula. Most of the so-called “infrastructure” funding in the Stimulus Bill was allocated this way, allowing the feds to more or less wash their hands of the process and say, “we’ve allocated the money with lightening speed and it’s not our fault if the states are too dumb to spend it quickly.” These pass-through Stimulus Bill funds go the relevant agencies in each state, with highway construction funds to the State Transportation Department, water/sewer funds to the State Water Department, UFO landing strip construction funds to the State Department of Extraterrestrial Affairs, and so on. I will eventually write a detailed post on how states distribute funds, but I digress.
    • (2) If the program involves direct submission to the federal agency, the Program Officers draft a RFP/NOFA/SGA/FOA or what have you, which is the document that applicants will actually use as the guidelines for spinning their tales of woe and need. RFPs are sometimes published in the Federal Register, made available through Grants.gov, FedBizOpps.gov, and/or in even more obscure ways. As Jake has previously noted, Grants.gov is the central repository for all Federal grant information, except when it isn’t.**
  • Applicants prepare and submit proposals in response to the RFPs. This is what Seliger + Associates does endlessly. Depending on the funding agency, the amount of hysteria surrounding the grant program and the underlying problem it is supposed to solve, the length of time allowed for submission varies from about two weeks to three months, with 45 days being typical. In the case of new programs, where new regs and RFPs have been drafted, one can usually expect several modifications to the RFP to be published, as mistakes and inconsistencies are identified. Since we spend much of our time deciphering arcane RFPs, we often have the thankless task of letting the Program Officer know that they have screwed up their RFP. In making these calls, we usually receive snarls and growls, not attaboys in return. We don’t do this out of civic duty, but to protect our client’s interest by not having the Program Officer declare a do over and start the RFP process again.
  • Once the RFP deadline arrives, the process submerges into the murky waters of Washington, but the review process goes more or less as follows:
    • 1. Applications are “checklist reviewed” to make sure the applicant is eligible, the forms are signed, etc. In most cases, if the application is technically incorrect, it is summarily rejected. You do not pass Go and you do not get $200, but you will eventually get a charming “thanks for the lousy application” form letter. Certain funding agencies, such as HUD, may send a deficiency letter, giving the applicant one more chance to sign the forms or what have you.
    • 2. Applications that pass the technical checklist are reviewed on “merit.” These reviews can be done by the Program Officers, by “peer reviewers” (nonprofit and public agency managers lured to Washington by per diem and a $100/day honorarium) or by other Federal employees dragooned into the task. The last is the worst alternative, because the shanghaied bureaucrats will know nothing about the program and will be annoyed at having been roused from their slumber. Think of Smaug the Dragon in The Hobbit, who always slept with one eye half-open.
    • 3. The applications will be scored on some scale and, in most cases, allegedly against criteria in the RFP. The applications will be ranked by their score, at which point our old friend, politics, rears its ugly head again. Most RFPs contain language along the lines of “The Secretary reserves the right to make funding recommendations based on geography and other factors.” While the Secretary of Whatever can basically fund any agency she bloody well feels like, as a practical matter this means that the funds are spread to many states for applicants in big cities, towns and rural areas and for projects that are perceived to help certain populations of interest. One could have a highly ranked application but still not be funded due to the vagaries of the approval process. If it is good news, the applicant might get a congratulations call from their House Rep or Senator’s office before the notice of grant award letter shows up. Some our of clients have reported reading press releases in local papers from their elected representatives before they were officially notified of being funded. While most Federal agencies aim for about a 90 day review process, about three – nine months is more typical. Using six months is a good standard.
  • The grant award letter will include instructions to contact the Budget Officer who has been assigned to the application. This being the Federal government, the award being offered may be the exact amount requested, or less than requested, or even more than requested.
  • You’re not done yet because the applicant must “negotiate” a contract with the Budget Officer. If the Budget Officer thinks the budget originally submitted was not prepared in accordance with Federal budgeting rules, or is just having a bad day, he will demand that you modify your budget or prove that it is reasonable. I have lots of funny stories about this process, but will save them for future posts. After the budget is agreed, the rest of the contract is negotiated. Allow two months for the contracting process.
  • Congratulations, you’ve fallen across the finish line. Since Federal funds cannot usually be expended before contract is signed, most recipients will not begin project implementation until the money is actually available, so another three months can be added to hire staff, teach them where the restrooms are, arrange for donuts to be delivered for weekly staff meetings and the like. Keep in mind that, if the money is for construction of something, add additional time for environmental reviews, permits, bidding and yet more contracts!

How much time is likely to go by before funds for new programs in the Stimulus Bill actually start stimulating something other than reporter’s imaginations? Adding it all up, I’ve got:

  • 3 months to develop regulations
  • 2 months to develop the RFP
  • 1.5 months for submission of applications
  • 6 months for application review
  • 5 months for contracting/start-up activities

If all goes right—and it almost never does—it takes at least one year for a Federal grant program to move from congressional approval/budget authorization to walkin’ around money for nonprofits. Keep in mind that this is for a program involving direct Federal competition. In the case of state pass-through programs, an additional one to three years can be added, depending on state budgeting and other processes. We’ll be writing “Stimulus Bill” proposals in the twilight of President Obama’s first term!

* As George Bernard Shaw famously quipped, “The government who robs Peter to pay Paul can always depend on the support of Paul.”

** The CDFI Program is a good example of how Federal agencies sometimes “forget” to publish their grant opportunities in grants.gov or the Federal Register. As noted above, the Department of the Treasury received $100 million in extra Stimulus Bill funds for this program and decided to use $45 million to fund additional applications for the last funding round, which closed in October. The funding announcements for the October round have not yet been made, so for those of you counting, six months has gone by since the application deadline. Even though there is much gnashing of teeth in the media about banks not lending, the Treasury Department itself is taking forever to get its funds on the street.

The other $55 million in CDFI Stimulus Bill funds have been set aside for new applicants in a supplemental funding round, which has been rumored for two months. The NOFA was finally issued on April 21, with a deadline of May 27, but was only placed on an obscure part of the CDFI web site, if one drills down to “News and Events.” It is not listed on the “How to Apply Page,” which includes timely info on the deadline for last October. Nor was it published on Grants.gov or in the Federal Register. If there are any aspiring Woodward or Bernstein type investigative reporters out there, you might want to find out why the Department of Treasury did as little as possible to let potential applicants know about this very sweet pot of gold. With all the fuss and bother over the Stimulus Bill, one would have thought the Department of the Treasury would have been trumpeting the availability of these funds.

Posted on by — 1 Comment

A Primer on False Notes, Close Reading, and The Economic Development Administration’s (EDA) American Recovery and Reinvestment Act (ARRA) Program, or, How to Seize the Money in 42 Easy Steps

All three of you masochistic enough to read the Federal Register on a regular basis might have noticed that the Economic Development Administration (EDA) posted a couple of notices about the American Recovery and Reinvestment Act of 2009 Recovery Act Funding, which exemplifies many of the trends we’ve been discussing while also showing that it’s business as usual at EDA. To explain why this announcement is particularly sneaky, we’ll have to explain it and how EDA works.

The Grants.gov notifications says:

EDA is soliciting applications for the EDA American Recovery Program under the auspices of [the Public Works and Economic Development Act of 1965] PWEDA. Specifically, the [RFP] pertains to applications for funding under EDA’s Public Works and Economic Adjustment Assistance programs only.

Ah ha! Money for economic development and job training. This sounds like a new program—but it’s not, or at least not as new as it sounds. To the uninitiated, this seems like a standard announcement for a federal program except for the rolling deadline. The sneaky part comes from the way EDA funds projects: rather than accepting a batch of proposals in response to a set deadline/RFP process, grading them, and then issuing funding notices, EDA requires that you apply to the “Economic Development Representative” (EDR) for your region (you can find a list of them at the bottom of the “Announcement of Federal Funding Opportunity” (FFO) (warning: .pdf link), which is yet another way of saying RFP). EDA has used more or less the same byzantine funding system since the late 1960s, which the application explains on pages 12 – 13 with all the traditional clarity of federal lingo. We’ll break it down in steps:

Each application package is circulated by a project officer within the applicable EDA regional office for review and comments. After all necessary information has been obtained, the application is considered by the regional office’s investment review committee (IRC), which is comprised of regional office staff. The IRC discusses the application and evaluates it…

So you submit the application, the EDR reviews it, and “checks it for eligibility,” according to Arizona and Western Washington EDR Jacob Macias, who I spoke to via phone on Wednesday, March 11 (he’ll appear later in this story).

Assuming your EDR accepts the initial proposal:

The IRC recommends to the Regional Director whether an application merits further consideration, documenting its recommendation. For quality control assurance, EDA Headquarters reviews the IRC’s analysis of the project’s fulfillment of the investment policy guidelines set forth below … After receiving quality control clearance, the Selecting Official, who is the Regional Director, considers the evaluations provided by the IRC and the degree to which one or more of the funding priorities provided below are included, in making a decision as to which applications merit further consideration.

To summarize: you submit the application to the EDR. The EDR obtains the necessary information. The IRC reviews the application. If the IRC thinks your app is kosher, it goes to the Regional Director, and, apparently, to the EDA’s headquarters. Oh, yeah, and:

To limit the burden on the applicant, EDA requests additional documentation only if EDA determines that the applicant’s project merits further consideration. The Form ED-900 provides detailed guidance on documentation, information, and other materials that will be requested if, and only if, EDA selects the project for further consideration. EDA will inform the applicant if its application has been selected for further consideration or if the application has not been selected for funding.

That bolded section is critical. In words other than those used by the RFP, the initial submission is really a pre-application: you’ll be submitting what amounts to a letter of interest or a letter of intent to the EDR, along with a few forms, to see if he or she (I’ll go for “he,” since I spoke with Macias) wants you to submit a full proposal. If he doesn’t, you’re screwed. He’s the first gatekeeper. When potential clients call to discuss applying to EDA, Isaac tells them that they effectively have to be “invited” by their EDR, since if they’re not invited in some way there’s no point in chasing EDA money; only if the EDR likes your project, you have juice in Washington, or you have juice with the Regional Director should you pursue it. Once you’re invited to submit a full proposal, in most cases, the project will eventually be funded, although it may languish in the pipeline waiting for EDA to get additional appropriations.

But if you don’t read the passage above carefully and know how EDA tends to work, you might end up submitting a full proposal that’ll never be funded. And one reason you need your EDR behind the project is that EDA already has a bunch of proposals that could be sped or slowed or funded or not at the pace of EDRs. When I called Macias earlier this week, he said that he had “a number of proposals in here” in various stages of completion that need to be “cleaned up” or are missing documentation or whatever.

Unlike other federal proposals, with EDA you don’t just send everything you’ve got and that’s that: there’s a bunch of back and forth. Suddenly, the standard deadline system of most federal grant programs begins to look pretty good, since they’re built on the gladiator model in which the Emperor (or, in this case, program officer) simply gives your project a thumbs up or thumbs down. You enter the grant arena, say “Morituri te salutant” (“Those who are about to die salute you”) and find out what happens.

Anyway, Macias thinks that “maybe five” EDA applications have been sent to DC and still not wholly funded. There are seven EDRs for the Western region. If he’s representative of the whole, that means there are 35 or more applications sent to Washington D.C. but still unfunded. And that’s only a single region, which includes the megatropolis of California, where there are no doubt more projects than Arizona and Western Washington. Macias couldn’t even tell me how many projects had been submitted in the Western Region. He’s probably right that no one really knows the answer; it could be as high or as low as the EDRs want it to be, or as high and as low as the funding allows. The important thing from the perspective of an applicant is that some of those projects being “cleaned up” could probably be cleaned up really, really quickly if necessary.

Another question: why does no one know the answer to this question? Wouldn’t it be in EDA’s best interest to know so they can plan accordingly? Wal-Mart tends knows how many pairs of socks it has at every location and Dell magically gets almost every computer order right. But the EDA doesn’t seem to know, or at least Macias isn’t telling if they do, but I’d tend to take his assertion at face value. In the new found federal interest in transparency, one wonders why EDA doesn’t just post a list of pending projects by region on their website, so that applicants could better determine their chances of being funded before cozying up to the EDR with flowers and chocolates. I may submit a FOIA request to EDA to see just how many projects are already waiting to be funded and how that compares to the amount of money just announced. When I get an answer, I’ll post it.

Whatever the number of unfunded EDA projects, it’s probably high enough that, with a stimulus-related cash infusion, EDA could probably simply fund more projects in the pipeline rather than encourage new proposals if the organization felt so inclined. So your EDR better believe in your project if you want to be funded. That’s just how it goes, and the RFP is something of a slight-of-hand trick, since you still have this Texas two-step to get the money. The EDA programs are continuing opportunities for which there always some amount of funds available. Thus the announcement in question is misleading, if not outright disingenuous.

But if you haven’t been dealing with EDA for years, you wouldn’t know the deal and might take the announcement at face value. Isaac confirmed the actual nature of the EDA beast in a conversation he had this week with highly placed manager in a state economic development office, which is considering hiring us to write some of their ARRA proposals. The topic turned from the Department of Labor to EDA, at which point this fellow, who also has years of experience with EDA, described EDA as a “heiney-kissing” exercise requiring lots of trips to the regional office to sweet talk the EDR and Regional Director.

 

These EDA issues are also indicative of what Isaac wrote earlier in “Stimulus Bill Passes: Time for Fast and Furious Grant Writing“:

… [I]t’s going to take quite a while to get the money to the streets. Most Federal agencies usually take anywhere from three to six months to select grantees and probably another three months to sign contracts. My experience with Federal employees is that they work slower, not faster, under pressure… there are no bonuses in the Federal system for work above and beyond the call of duty.

This program shows how long it will take the funds to hit the street for a new applicant, since the EDA pipeline is frequently a long one, running as it does from the local EDR to the Regional Director to Washington back to the Regional Director and back to Washington, with each one taking a piece along the way;* it’s like writing a dissertation, in which every committee member must be satisfied before you can graduate.

In addition, notice some key words in the EDA’s initial, March 5 announcement of the Recovery Act Funding: “[I]t takes a minimum of 90 days from EDA’s receipt of a complete application until award, when funds are obligated.”

There’s also another other curious thing about this March 5 announcement: it was an announcement of an announcement: “Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA.” This is like sending an announcement of a forthcoming invitation to a party—why not simply make the announcement, especially since the two followed each other within days? The situation could be fundamentally irrational, or there could be some unknown statutory requirement hidden in the legislative language, or someone at the EDA could have simply been tipsy while entering Grants.gov information.

The answer came from an EDA representative. Isaac traded some emails with Jamie Lipsey, the EDA contact person, about the pre-announcement announcement. She sent back the following to his initial query:

Under a forthcoming federal funding opportunity (FFO) announcement, EDA will solicit applications for the EDA American Recovery Program under the auspices of PWEDA. Specifically, the forthcoming FFO will pertain to applications for funding under EDA’s Public Works and Economic Adjustment Assistance programs only. EDA will not accept applications until the FFO is published. The FFO will be posted on www.grants.gov as soon as it is available.

When Isaac replied by essentially saying, “huh?”, Lipsey simplified it to this:

Perhaps I should have summed up: under the Recovery Act and guidance provided by the Office of Management and Budget (OMB), EDA was required to post the status of our recovery announcement on www.grants.gov by March 5, 2009. I believed the posting did that clearly in stating that the FFO announcement was forthcoming and that applications would not be accepted until it was published, which should happen next week.

Ah: so EDA got around the deadline through the pre-announcement. As so often happens, the agency protects its turf and itself, effectively executing the pre-announcement as a cover-your-ass (CYA) maneuver with the beauty of a dancer’s pirouette. I gave this post a long and convoluted title in honor of the length necessary to explain what the EDA is actually like.

Despite all the issues discussed above, EDA grants are still very much worth applying for, and if you’re interested in doing so you should call us. Isaac has been writing funded EDA applications for 30 years and knows how to warm the stone-like hearts of the elusive EDRs.

 

* Actually, the EDA application process can be even more complicated than summarized above and described in the FFO. In many cases, before the EDR will accept a pre-application, the project has to be ranked in the regional Community Economic Development Strategies (CEDS). The CEDS process replaced the former process, which was called the Overall Economic Development Planning (OEDP) process, in 1999. The FFO is silent on the subject of CEDS. Perhaps CEDS has gone the way of the OEDP, or maybe EDA is saving this nugget for the EDRs to drop on applicants. EDA is like the lyrics of the theme song of the 1968 movie classic (and the dopey 1999 remake), The Thomas Crown Affair, Windmills of Your Mind: “Round, like a circle in a spiral, Like a wheel within a wheel / Never ending or beginning / On an ever spinning reel …”.

Federal, State, and Program Acronyms for Grant Writing (and Writers)

Grant writing, like virtually any activity that involves bureaucracies, uses numerous acronyms. Something about governments makes them particularly fond of acronyms; Elmore Leonard even mocks that tendency in his novel Road Dogs. For novices, acronyms and jargon form an opaque barrier, but over time they become a language unto themselves, separating initiates from masters. Below, you’ll find a handy guide to the many acronyms used in Grant Writing Confidential (GWC) and the Seliger Funding Report E-Mail Newsletter. The guide includes federal agencies/departments, processes, large grant programs, and the like, all of which you’re likely to encounter here and elsewhere. In posts on GWC, acronyms used are usually defined, but sometimes one slips by.

Here are some that we often use (more acronyms will be added over time; if you have a suggestion, don’t hesitate to e-mail Jake Seliger):

ARRA: The American Recovery and Reinvestment Act of 2009: The Federal legislation authorizing billions of dollars in program funding and tax cuts, referred to originally as the “Stimulus Bill,” “Stimulus Package,” or “HR 1.”

BEDI: Brownfields Economic Development Initiative: A large HUD program designed to rehabilitate brownfields, which are former industrial or otherwise environmentally compromised sites. Note that the applicant must be a CDBG formula recipient and the grant is tied to a loan, called a Section 108 Loan. The security for the loan is the jurisdiction’s future CDBG allocation. As a result, there are few takers for BEDI grants or the counterpart EDI, which is the same kind of program but without the Brownfields requirement.

CA: California: A state abbreviation. State abbreviations usually follow postal codes.

CBO: Community-Based Organization: An organization that provides human services and is embedded within a particular community or population. In contrast to Faith-Based Organizations (see below), CBOs don’t have a religious affiliation.

CDBG: Community Development Block Grant: A pass-through HUD program that allocates funding to “entitlement cities and counties”, as well as states for smaller cities and rural areas, on a formula basis; funds can be used for a variety of affordable housing, economic development, infrastructure and other projects.

CFR: Code of Federal Regulations: The rules and requirements published by administrative agencies and departments, like HUD, the Dept. of Education, and the like. Or, to use the state description, “the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government.”

CMW PEP: The Carol M. White Physical Education Program: A federal program designed to increase physical fitness participation and promote healthful eating habits among school-age children by funding physical education activities during the school day and after school.

CoC: Continuum of Care: Authorized under the several “McKinney Act” Programs administered by HUD, Continuum of Care funds are allocated at the local level by regional “Continuum of Care” agencies (see “LAHSA” below) to provide an array of services to the homeless.

CSBG: Community Services Block Grant Program: A pass-through Office of Community Services (OCS) program that allocates funding to “entitlement cities and counties”, as well as states for smaller cities and rural areas, on a formula basis; funds can be used for a variety of human services, job training and other projects that benefit low-income persons.

DHHS: Department of Health and Human Services: The federal department charged with activities related to its name, or, in the grandiose vision of whoever wrote the department’s own description, the “principal agency for protecting the health of all Americans and providing essential human services, especially for those who are least able to help themselves.”

DOC: Department of Commerce: The federal department charged overseeing commercial activity.

Dept. of Education: The federal department charged with overseeing education. Note that it is seldom referred to as the “DOE” because that acronym was usurped by the Department of Energy, as shown below.

DOE: Department of Energy: The federal department charged with overseeing issues relating to energy production, consumption, and research. This shouldn’t be confused with the Department of Education, which is usually written as Dept. of Education or by its full name, unless otherwise noted.

DOL: Department of Labor: The government agency that “is charged with preparing the American workforce for new and better jobs.” Its authority sometimes overlaps with the DOC’s.

EDA: Economic Development Administration: The federal department charged with increasing jobs, providing skills training, and the like, by funding economic development activities, including infrastructure.

EHB(s): Electronic Handbook(s): HRSA’s acronym, which often appears in the plural, for a full electronic submission package. The deadline for an EHB is often later than the Grants.gov submission deadline. I have no idea why HRSA didn’t choose “EH” as the acronym for “Electronic Handbook.”

FBO: Faith-Based Organization: An organization that provides human services but is affiliated with a religion or movement. These organizations are generally separated from a particular religious body itself (i.e. the church, synagogue, mosque, temple, etc.), but still can retain ties to that body. Although FBOs cannot use Federal funds for religious activities or restrict access to services based on the religion of recipients, services are often provided from their religious point of view.

FEMA: The Federal Emergency Management Agency: Now a sub-organization of the Dept. of Homeland Security, FEMA is “tasked with Disaster Mitigation, Preparedness, Response and Recovery planning.” In reality, its tentacles extend far beyond that mission.

FFO: Federal Funding Opportunity: This is yet another way to say “RFP,” or announce that that funding is available.

FHA: Federal Housing Administration: A sub-organization of HUD, the FHA “provides mortgage insurance on loans made by FHA-approved lenders throughout the United States and its territories.” In effect, it often subsidizes housing purchases and building.

FOA: Funding Opportunity Announcement: This is another acronym for “RFP,” or announce that funding is available.

HUD: The Department of Housing and Urban Development: The federal department charged with overseeing issues related to housing, including Section 8 vouchers, public housing, FHA financing, and the like.

IHE: Institute of Higher Education: A post-secondary school responsible for education after grade 12. This could be a technical institute, two-year community college, four-year college, or a university.

LAHSA: Los Angeles Homeless Services Authority: The joint Los Angeles city and county organization is charged with addressing homelessness issues in L.A. County. It is primarily funded through “Continuum of Care” (see above) grants from the “McKinney Act” Programs, administered by HUD, on a formula, pass-through basis.

LEA: Local Education Agency: This is usually a long way of saying “school district,” or the city/county agency charged with overseeing K – 12 education. Sometimes individual public charter schools can function as independent LEAs, depending on the law in their particular state.

NOFA: Notice of Funding Availability: This is synonymous with “RFP” and means a document issued by a funder to solicit proposals.

NSF: National Science Foundation: The federal department charged with improving and researching science and technology.

OJJDP: Office of Juvenile Justice and Delinquency Prevention: The Department of Justice office responsible for distributing federal formula grants to the states for various juvenile justice programs. OJJDP also administers a number of direct competitive grant programs and periodically issues RFPs for them.

PWEDA: Public Works and Economic Development Act: This 1965 act authorizes many EDA activities and sets guidelines for how EDA’s money is supposed to be spent.

RAT Board: Recovery Accountability and Transparency Board: The organization charged with investigating fraud and abuse at federal agencies. See more here.

RFA: Request for Funding Assistance: This is synonymous with “RFP” and means a document issued by a funder to solicit proposals.

RFP: Request for Proposals: This is the basic acronym that we use indiscriminately to describe documents that offer guidelines for grant funding. That the federal government has invented four terms for the exact same idea/process is a microcosm of larger problems associated with taming the federal bureaucracy (see “SGA,” below, for the fourth term).

SAMHSA: Substance Abuse and Mental Health Services Administration: A large sub-organization of DHHS responsible for conducting the kinds of programs its name implies it would conduct.

SEA: State Education Agency: State-level government organizations that oversee education.

SF-424: Standard Form 424: This is the basic cover form for most federal grant applications. Even though it is supposed to be a “Standard Form,” different agencies, such as Department of Education, use variants of the SF-424. Also, SF-424s included in grants.gov application files are different than the paper versions. So, SF-424s are not “standard”.

SGA: Solicitation for Grant Applications: Like a Request for Proposals (RFP), an SGA is a document issued by a funder to solicit proposals.

STEM: Science, Technology, Engineering, and Math: This acronym is most common in NSF and Dept. of Education programs, as both organizations frequently publish RFPs involved with STEM-related subjects.

TX: Texas: Another state abbreviation.

WSJ: The Wall Street Journal: One of the two best daily newspapers in the United States, the other being the New York Times.

In addition to learning lots of acronyms, it also helps to have a strong working knowledge of how government is organized if you’re going to understand the grant process. If you, like many of us, slept through or never experienced the relevant portion of your civics class, a variety of books, pamphlets, and websites describe how governments operate, but we like Rulemaking: How Government Agencies Write Law and Make Policy and Politics and the Bureaucracy. Neither sounds exciting, but either would be helpful if you’re looking for a crash course in levels of government and their functions, which is essential if you’re going to understand grants, grant writing, this blog, and, ultimately, how to make sure your agency is funded.

Posted on by — Leave a comment

Blast Bureaucrats for Inept Interpretations of Federal Regulations*

Jake received an email response to “FEMA and Grants.gov Together at Last” from a firefighter who is working on a Assistance to Firefighters (AFG) proposal who seems to have been given a bum steer by AFG Program Officer and Jake’s nemesis, Tom Harrington (for background, see “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats” and the hilarious e-mail exchange with Mr. Harrington). According to our email correspondent, Mr. Harrington, the AFG contact person, said that vendors can’t help fire departments prepare grant applications, because he thinks this is forbidden by 44 CFR Part 13.

Is Mr. Harrington correct? A quick review of 44 CFR Part 13 reveals that it concerns uniform administrative requirements for grants to state and local governments. While the section contains lots of fascinating requirements, it is utterly silent on the ethics of who writes or pays for a grant proposal—which is not surprising, since I have never seen any Federal regs or RFPs that would preclude an applicant from getting help in grant writing, paid or volunteer.

While Mr. Harrington seems stuck on 44 CFR Part 13, I think he probably means Office of Management and Budget (OMB) Circular A-87, which covers cost principles for state, local and tribal governments and specifies how Federal lucre is to be spent. A key aspect of A-87 and grant administration in general is that, in addition to following Federal rules, public agencies must hew to their own procurement rules while squandering grant funds. As one who had several local government posts along the way, the most recent being the Community Development Director for the City of San Ramon in the early 1990s, and managed lots of federal and state grant funds, it basically comes down to the “smell test:” if you would not want your mother to read about how you spent Federal funds on the front page of the New York Times, don’t do it.

Federal regs don’t prevent a public agency from receiving grant writing help from others, including a potential vendor, but Mr. Harrington simply doesn’t like the idea and is intimidating AFG applicants by vague threats of dire consequences from scary sounding CFR citations. In other words, Mr. Harrington is probably a bureaucrat bully. Just like Clint Eastwood confronting Gene Hackman’s thugs in The Unforgiven’s saloon scene,** the only way to deal with bureaucratic bullies is to metaphorically blast away by reviewing the regs in question and, when one is satisfied that the threat is an illusion, sweetly asking the bureaucrat to cite chapter and verse to support his position. When he can’t follow through, you’ve got ’em.

Mr. Harrington is probably wrong, but his obstinate response illustrates an important point about dealing with agency contacts in general: although they can give you guidance, what’s written in RFPs ultimately counts. If something a program officer says contradicts the language of an RFP, assume the RFP is right. This can also work against you: if a program officer says that you don’t need a particular form, or that going over the page limit is acceptable, or that you don’t need to follow formatting requirements—all of which might make your life easier—don’t listen. Follow what you can read. Sometimes you’ll find internal contradictions in an RFP, and if so, contact the program officer and cite the conflicts, complete with page numbers and why you think a conflict exists. This may result in a modification to the RFP. But don’t assume that the verbal assurance of someone in the program will count for any more than the paper they’re written on.

Now that I’m satisfied that Mr. Harrington is pursuing his own agenda, rather than providing clear direction based on the regs, let’s examine the underlying ethical issue in juggling these rules and principles. While we do not go out of our way to be hired by vendors to prepare grant proposals for third party applicants, this does happen from time to time. For example, this almost happened with the current Carol M. White Physical Education Program (CMW PEP) RFP, which I blogged about in Brush the Dirt Off Your Shoulders: What to Do While Waiting for the Stimulus Bill to Pass. A large fitness equipment vendor called for a fee quote to have us write CMW PEP proposals for several of their school district clients. I explained that we would be happy to write the proposals as long as the vendor understood we would be working for the school districts, not colluding in getting their products purchased. I pointed out that their products would not be highlighted by brand name in the proposals, and the school districts would still have to follow applicable Federal regs, OMB circulars and their own purchasing rules.

If a vendor wants to try to rig bids, that’s there prerogative and they’ll ultimately be punished. As grant writers, our job is just to write ’em without resorting to unethical acts or breaking laws. To quote Bob Dylan quoting Hurricane Carter regarding how Carter felt about being a boxer, “It’s my work, he’d say, and I do it for pay.” A program officer like Mr. Harrington should no more care about who writes a proposal any more than he should care who fixes the applicant’s plumbing when it backs up. The punch line, of course, is that the vendor didn’t hire us for the CMW PEP, although we have written a few funded proposals under similar arrangements over the years, including one of my favorite Federal programs that is soon to get a huge influx of new money courtesy of the Stimulus Bill: Community Oriented Policing Services (COPS). If an applicant for any grant, however, is concerned about legal and ethical questions, they should ask for an opinion of law from their lawyer, not depend on random off-the-cuff interpretations by program officers.

Mr Harrington’s prejudice against grant writers has a long pedigree. Over the years, I’ve often come across the misguided conception that using an outside grant writer is somehow “cheating.” Way back in 1993 or so, when we were first in business, I tangled with a HUD Deputy Under Assistant Secretary about the then-new YouthBuild program regulations. When he discovered that we were grant writers working for a South Central LA nonprofit, he went ballistic and and accused me of “only wanting to line my pockets.” I responded by asking him if he was a volunteer and if he would like me to request his salary level and travel reimbursements through a Freedom of Information Act (FOIA) request. This calmed him, I got the interpretation of the regs I needed, and the proposal was ultimately funded. If you want to put the best face on your next grant proposal, call a qualified grant writer to apply proposalese makeup to make your application sparkle. While we do sometimes turn down assignments, it is not for the reason imagined by Mr. Harrington, but rather for real ethical problems determined by applying the simple smell test described above. You can also apply the smell test to bureaucrats, and if what they pitch seems wrong, it often is.

* The bureaucrats I am needling in this post are Federal program officers, who are also featured in my last post, Stimulus Bill Passes: Time for Fast and Furious Grant Writing. Not to worry: no Program Officers were actually harmed in the writing of this post.

** The Unforgiven is by far the best modern Western. As Clint’s Bill Munny responds to an accusation of being a “cowardly son of a bitch” for shooting an unarmed bartender in the saloon scene, “Well, he should have armed himself if he’s going to decorate his saloon with my friend” (the dead Morgan Freeman). Words to live by in challenging bureaucrats, who often only arm themselves with self-importance and don’t take the time to understand their own regs.

Posted on by — 1 Comment

FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program

Last year I railed about the Federal Emergency Management Agency’s inability to post the Assistance to Firefighters Grants program RFP on Grants.gov in a timely fashion in “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats.” In addition, I sent a nastygram to FEMA about this failure, which someone named “R. David Paulison” responded to seven months later, as noted in the third bullet of January Links. That it took seven months to respond to a letter complaining about timeliness might be indicative of further problems.

You might imagine that FEMA would’ve solved the problem this year—in which case you’d be wrong. The Assistance to Firefighters Grant (AFG) Program 2008 Fire Prevention and Safety Grants (warning: link goes to a .pdf) program RFP was issued on Jan. 29, but it’s still not on Grants.gov as of this writing. Furthermore, the RFP doesn’t even include a Catalog of Federal Domestic Assistance (CFDA) number attached—which it should, since, according to the CFDA website, “As you know, the CFDA provides a full listing of all Federal programs available […]” and all federal programs are supposed to have a CFDA number in the body of their RFPs.

(As an aside: the CFDA website isn’t working at the moment because “We are upgrading our site to provide increased transparency, greater access to assistance information and to better support the American Recovery and Reinvestment Plan.” Isaac tried to visit it earlier this week and found it dead. This is somewhat strange because every other website, including ours, would leave the old version up until the new one is ready to go; only the government would take down the old website and leave nothing in its place. I’ve never seen Amazon.com intentionally prevent me from buying books because they wanted to improve the interface. Keep this in mind when contemplating the various proposals that have been floating around regarding government-mandated electronic medical records.)

Nonetheless, a print version of the CFDA lists the AFG’s CFDA number as 97.044. I took that to Grants.gov’s search page and tried the CFDA number and variations on AFG. No dice. In other words, the CFDA and Grants.gov websites must not talk to one another, since AFG appears in the CFDA but not in Grants.gov. More importantly, FEMA still hasn’t posted the AFG RFP to Grants.gov. Maybe FEMA will three days before the deadline, as they did last year. I’m really glad Tucson isn’t susceptible to hurricanes.

But there is some good in this mess, which you can find on page 10 of the RFP: “Applicants are allowed to hire, or otherwise employ the services of, a grant writer to assist in the application process.” Great news! Great, but unnecessary—funders can’t prohibit or forbid grant writers; how you prepare your application is your own affair. Typically, you just can’t charge expenses to a contract before you have a contract to charge them to, and you can’t hire grant writers on a contingent-fee basis. But no ethical grant writer will work on a contingent-fee basis, as we explain in our FAQ.

Posted on by — 1 Comment

January Links: A Genuine Surprise in a Request for Plain English, no Free Grant Writing Lunches, and More on Specious Statistics

* We argued that There is no Free Grant Writing Lunch and You Won’t Find Writers for Nothing, and the New York Times in part explains why in When to Work for Nothing (answer: almost never). In addition, the article says you should seldom work for getting “paid in exposure.”

* Many of you probably read the disturbing article in the Wall Street Journal and elsewhere about how “Murders of Black Teens Are Up 39% Since 2000-01:”

The data confirm a pattern identified earlier this year by The Wall Street Journal, which found that while most communities in the U.S. were seeing a decline in homicides, many African-American neighborhoods were continuing to see an increase. The Northeastern University research shows that the pattern is more pronounced among juveniles.

What the article doesn’t tell you is that said murders have substantially—probably by more than half—since 1993. However, Freakonomics points out what’s wrong with the scaremongering implied in the WSJ:

This figure presents homicide rates by age for blacks from 1976 to 2007. The dominant pattern in this picture is the huge spike in black youth homicides in the early 1990’s. The phenomenon captured in the scary New York Times graphic above corresponds to the barely perceptible rise in the black circles at the far right of the figure.

[…]

According to U.S. Census data, the number of blacks aged 15 to 19 rose by about 15 percent between 2000 and 2007.

So even if any individual black teen’s propensity for crime was unchanged over this time period, the aggregate amount of black-teen crime would have risen by 15 percent. In other words, in that New York Times graphic on perpetrators, just based on changes in population, the number of perpetrators would have been expected to rise from a little over 800 to nearly 1,000. Knowing that, the actual rise to roughly 1,150 doesn’t seem that noteworthy.

Nonetheless, if you’re writing a proposal, you’d do well to ignore the sensible Freakonomics pieces and quote the WSJ or NYT liberally, since they are authoritative and your chief responsibility is making sure that your grant story gets the money.

* In April 2008, we wrote a post on FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats, in which I described FEMA’s failure to use Grants.gov to announce the Assistance to Firefighters Grants program; the post illustrates the problems discussed in Grants.gov Lurches Into the 21st Century.

To FEMA’s credit, an administrator named R. David Paulison responded to a letter I sent, and Paulison said that FEMA disseminated information about the Assistance to Firefights Grants program through other channels. But, if I send him the firefighter department I’m associated with, he’d consider allowing a late application. Obviously I’m not associated with a fire department, but perhaps this means FEMA will issue the announcement on Grants.gov in a timely manner next year. Still, the letter Paulison sent me is dated December 5, indicating that perhaps FEMA’s tardiness problems haven’t exactly been solved, given that I sent my letter in April.

* Like the businesses they’re bailing out and the nonprofits they’re funding, federal and state governments are not looking good. Note in particular the last line of the linked post.

* RFPs are normally written in bizarre doublespeak, as we’ve amply documented. But in the DARPA Broad Agency Announcement NanoThermal Interfaces (NTI) MTO (warning: .pdf link), Isaac found something he’s never seen over 35 years and thousands of RFPs—a request for simplicity:

Statement of Work (SOW) – In plain English, clearly define the technical tasks/subtasks to be performed, their durations, and dependencies among them.

Presumably, the Defense Advanced Research Projects Agency (DARPA)—the same guys who laid the foundation for the Internet—has among the brightest technical lights in the U.S. government working for it. If they request sections of highly technical proposals in plain English, perhaps the Department of Education should learn something from them, instead of ceaselessly requiring proposals written in educrat. Foundation proposals will occasionally request summaries or even proposals in relatively clear language, but more often than not, their guidelines look as though HUD rejects got into the review process.

Sometimes one will find proposal narrative guidelines almost as long as the page limits on the narrative itself; I can’t think of an immediate example save YouthBuild, as the narrative section of SGA is about 17 double spaced pages for 20 pages of required narrative. Finding another example would require digging through the voluminous (albeit digitally so, these days) RFP archives that make even seasoned grant writers blanch. Regardless, when you can find a request for real writing, savor it: you’ve got a rare dish you won’t taste often.

* Occasionally we’ll post examples of bureaucratic silliness and obtuseness, and I ran into a great example with the The Service Area Competition – Additional Service Areas funding opportunity. If you read the “Additional Information on Eligibility” section, you’ll see that it defines eligible applicants as “Public or nonprofit private entities, including tribal, faith-based and community-based organizations; and Organizations proposing to serve the same service area and/or populations identified in Appendix F,” without saying what the program is actually designed to do. And two paragraphs mention Appendix F at least half a dozen times. So I downloaded the 153-page file and searched for Appendix F, expecting a cornucopia of possible applicants but instead found four: La Pine, OR, Charleston, SC, Marchester, NH, and Miles City, MT.

Wouldn’t it have been easier simply to write those four applicants in the description on the website? And what makes these incredibly narrow areas important enough to justify their own funding announcement? I don’t know for sure, but if I were to wager, I would guess that HRSA, for whatever reason, wants to wire money for specific organizations in each area, and that whichever organizations know they’re getting the money just need to turn in something mostly correct to collect.

* A point Isaac has made many times in private now finds expression on a blog: senior bureaucrats, not political appointees, really run things in Washington.

* The New York Times discusses the “Evidence Gap” in “Drug Rehabilitation or Revolving Door?“, with the article strongly implying “revolving door.” Note this piece:

Yet very few rehabilitation programs have the evidence to show that they are effective. The resort-and-spa private clinics generally do not allow outside researchers to verify their published success rates. The publicly supported programs spend their scarce resources on patient care, not costly studies.

And the field has no standard guidelines. Each program has its own philosophy; so, for that matter, do individual counselors. No one knows which approach is best for which patient, because these programs rarely if ever track clients closely after they graduate.

(Emphasis added. We’ve discussed why that is in Studying Programs is Hard to Do: Why It’s Difficult to Write a Compelling Evaluation and, to a lesser extent, in What to do When Research Indicates Your Approach is Unlikely to Succeed: Part I of a Case Study on the Community-Based Abstinence Education Program RFP. The whole article illustrates the problems with evaluations that we describe in the two posts above.)

* New York Times columnist Nick Kristof describes what might be called the charity paradox, whereby those who do good deeds are supposed to be utterly saintly while those in business are supposed to be utterly rapacious, in The Sin in Doing Good Deeds. The column, naturally, attempts to reconcile the two. We discuss similar issues in Foundations and the Future, which was published about a year ago.

* More on questionable abstinence studies, this time from the Washington Post, which says “Premarital Abstinence Pledges Ineffective, Study Finds; Teenagers Who Make Such Promises Are Just as Likely to Have Sex, and Less Likely to Use Protection, the Data Indicate.” Read What to do When Research Indicates Your Approach is Unlikely to Succeed: Part I of a Case Study on the Community-Based Abstinence Education Program RFP for more on the smoke surrounding abstinence education, whether in favor or against. Remember too that, if you’re writing a proposal for an abstinence program, Your Grant Story Needs to Get the Money—so if the data don’t support the RFP you’re writing for, don’t use them.