Tag Archives: AFG

FEMA’s Assistance for Firefighters Grants (AFG) Appears On Time

Years ago we had a series of spats with the Assistance To Firefighters Grants (AFG) program contact person, for reasons detailed in “Blast Bureaucrats for Inept Interpretations of Federal Regulations* and “FEMA and Grants.gov Together at Last,” both of which have a lot of complaining but also have a deeper lesson: it pays to make noise when federal and other bureaucrats aren’t doing their jobs. If nothing else, the noise makes it more likely that those bureaucrats will do their jobs right in the future.*

For us, that future is now. A new AFG RFP was just issued. While it has a short 30-day deadline, it appeared in the Grants.gov database in a timely manner. Now fire departments that want to apply will have a fair shot. And pretty much every fire department should apply: there are 2,500 grants available. I don’t know how many fire departments there are in the U.S., but I do know that 2,500 is appreciable portion of them and that 2,500 isn’t a typo—at least on our part.


* Plus, complaining is sometimes satisfying.

The Feds dumped RFPs right before Christmas

I have the misfortune of reading the Federal Register each day, which is every bit as scintillating as it sounds.* This week I noticed that at least two dozen RFPs were released on December 23—the Friday before Christmas.

The timing probably isn’t coincidence—much of the nonprofit world effectively shuts down between Christmas and New Year’s every year (although we usually get a couple of calls from unusual nonprofits who are thinking about their next moves as the year winds down). The various agencies who issued RFPs know as much. They might have some internal reason for issuing RFPs when they did. But I’m skeptical and suspect that they wanted to bury some of these notices.

Which means you should take a closer-than-usual look. If you do, you’ll find some very interesting RFPs, like the Community Development Financial Institutions Program (CDFI; it has has $123,000,000 available with more than 100 grants to be made) or the Assistance to Firefighters Grant Program Fire Prevention and Safety Grants (AFG; it has $35,000,000 available and more than 200 grants to be made).**

Government entities, corporations, and other organizations routinely release bad news on Friday afternoons, when they know the bad news will get less press. We’re likely seeing a similar dynamic here, especially because you can just about guarantee that program officers contacts won’t be available until after the New Year. Incidentally, if you’re looking for politically unpalatable regulations, this is also an excellent time of year to be studying the Federal Register.

The Federal Register offers useful insights into the federal process at work, and the minds behind this process. This aspect of our business helps us build weird bits of insight that we’d otherwise lack and that we’re happy to share with you.


* If that weren’t enough, I’m also on all sorts of foundation and state e-mail lists. The result is usually tedium, intermixed with the occasional major grant opportunity.

** AFG is a program of special interest to me for reasons explained in “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats” and its sequels. As those posts describe, Seliger + Associates is doing its part to bring YOU better government.

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.

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. In discussing this post with my partner and wife, Kathy Seliger (a lucky woman, she gets to hear my pontifications 24 hours a day), and she pointed that hiring a grant writer is no more cheating than a woman wearing makeup to look her best. 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.

FEMA and Grants.gov Together at Last

Last week I complained that FEMA still hadn’t posted the Assistance to Firefighters Grant (AFG) Program 2008 Fire Prevention and Safety Grants to Grants.gov, which particularly rankled after last year’s fiasco.

My post went up on February 1, and lo! on February 2, the FY2008 Fire Prevention and Safety Grants program appeared on Grants.gov. And it only took a single e-mail to FEMA and last year’s contact person, Tom Harrington.

For those of you who are interested, the prodding e-mail I sent said:

Last year, I wrote to Tom Harrington, the AFG contact person, to ask why the AFG RFP didn’t appear in the Federal Register until three days before the deadline. We had an increasingly bizarre exchange about why the delay occurred, in which he gave a wonderfully nebulous response to my pointed questions about who was responsible for posting the announcement to Grants.gov: “I don’t know if there is anyone specific to blame; the process is to blame.” That exchange (see below for the whole thing) became the promised unflattering post on FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats.

This year, the AFG program RFP was released and, just like last year, didn’t appear in Grants.gov. What gives? Did the policy promised by Tom—”As soon as the policy is written, we’ll know. At this time, there is no policy.”—ever get written? If so, by who? If so, why wasn’t it written? This became the latest post on Grant Writing Confidential—FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program—and I would love to write a follow-up with your response.

As you can see from the About Grants.gov page, the site is supposed to be a central storehouse for grants information:

The concept has its origins in the Federal Financial Assistance Management Improvement Act of 1999, also known as Public Law 106-107. Public Law 106-107 has since sunset and is now known as the Grants Policy Committee (GPC). For more information on the Grants Policy Committee, click here.

The Grants Policy Committee’s Final Implementation Plan includes a policy product on page 6 that says one of its products will be a “policy on use of Grants.gov for mandatory grants” which will “Establish [… a] policy requiring agencies to post a description of funding opportunities for mandatory grants on Grants.gov.” Why is the Department of Homeland Security and FEMA hindering that effort?

This year’s unnamed contact person still hasn’t replied, which hurts my feelings, but at least I’ve inspired change you can believe in.