Posted on Leave a comment and deadline goofs

Isaac wrote about the dangers of online submissions in “ Lurches Into the 21st Century,” which says that real world deadlines should be at least two days before the actual deadline to ensure that your proposal is actually received. This will help you avoid latency and response problems when every other applicant rushes to upload their application at the last minute.

Occasionally goofs result in postings like one regarding the Department of Education’s Charter School Programs (CSP; CFDA 84.282A):

The original notice for the FY 2009 CSP competition established a January 29, 2009, deadline date for eligible applicants to apply for funding under this program. For this competition, applicants are required to submit their applications electronically through the Governmentwide site ( experienced a substantial increase in application submissions that resulted in system slowness on the deadline date. For this reason we are reopening and establishing new deadline dates for the FY 2009 competition for CSP. Applicants must refer to the notice inviting applications for new awards that was published in the Federal Register on December 15, 2009 (73 FR 76014) for all other requirements concerning this reopened competition. The new deadline dates are: Deadline for Transmittal of Applications: February 25, 2009.

The odd thing, of course, is that whoever operates must know deadline days will result in a submission flood, and yet when that flood predictably comes everyone seems flummoxed. Sometimes, but not always, the funding agency responds by allowing more time. It’s not apparent what factors, if any, or program personnel consider in deciding whether to extend the deadline, and this opaqueness means that you have to assume that no deadlines will be extended. Isaac wrote about a lucky circumstance in “Now It’s Time for the Rest of the Story:”

[…] our client didn’t even know that HUD had received the proposal until about two weeks before the funding notification. It seems that she did not receive the sequence of emails from confirming receipt of the proposal. She called and sent emails to and HUD, which generated responses along the lines of, “we can’t find any record of it.”* This went on for about two months. Adding to the festivities, it turned out that there were problems with other applicants that day at, so HUD re-opened the competition for a short period of time to allow these applicants to re-submit. Our client called the HUD Program Officer to discuss the re-submission process, at which point she was quickly told, “You don’t have to, we have your proposal and it’s already scored.” Two weeks later, she got a call from her congressman letting her know she’s been funded.

But you can’t rely on lucky circumstances. Just as the stimulus bill probably isn’t going to function as advertised and popularly portrayed and FEMA can’t seem to run the Assistance to Firefighters (AFG) program well, isn’t going to yield the efficiency gains it theoretically should. And if stimulus-funded programs begin pouring forth from Washington, the traffic on is only going to grow.

There’s a lesson to take from this: submissions are as arbitrary and disorganized as paper submissions, but it’s vastly harder to prove that you actually submitted a proposal using In modern times the postal system and FedEx have rarely—if ever—been so overwhelmed that they couldn’t deliver packages (exceptions being obvious weather issues like hurricanes), and even when they became overwhelmed, one can still show proof of submission. With, that luxury is gone. Be warned.

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Adventures in Bureaucracy and the Long Tale of Deciphering Eligibility: A Farce Featuring the Department of Education’s Erin Pfeltz

There are numerous good reasons why we often make fun of the Department of Education. One recently appeared in the Seliger Funding Report. Subscribers saw the “Charter Schools Program (CSP) Grants to Non-State Educational Agencies for Planning, Program Design, and Implementation and for Dissemination” program in the June 16 newsletter. The eligibility criteria for it, however, are somewhat confusing:

Planning and Initial Implementation (CFDA No. 84.282B): Non-SEA eligible applicants in States with a State statute specifically authorizing the establishment of charter schools and in which the SEA elects not to participate in the CSP or does not have an application approved under the CSP.

So we have two criteria:

1) States that authorize charter schools and

2) That don’t participate in the CSP.

Since it is not abundantly clear which states are eligible, the RFP also lists the states participating in the CSP:

Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Indiana, Kansas, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Utah, Wisconsin.

Great! But does the Department of Education have a list of those that authorize charter schools and don’t participate? To find out, I called Erin Pfeltz, the contact person, but she didn’t answer, so I left a message and sent the following e-mail as well:

I left a voicemail for you a few minutes ago asking if you have a list of states in which organizations are eligible for the “Charter Schools Program (CSP) Grants to Non-State Educational Agencies for Planning, Program Design, and Implementation and for Dissemination.”

If so, can you send it to me?

She replied a day and a half later, too late for the newsletter:

The information in the federal register notice includes a list of states which currently have an approved application with the CSP ( Non-SEA applicants in those states should contact their SEA for information related to the CSP subgrant competition. More information on the Charter Schools Program can be found at

I replied with some quotes from the RFP and then said:

The RFP gives us a list of states that do participate in the CSP. My question is whether you have a list of states that a) have authorized charter schools and b) do not have an application approved under the CSP.

In other words, which states do not authorize charter schools?

Erin responded:

States without charter school legislation are: Alabama, Kentucky, Nebraska, North Dakota, South Dakota, Maine, Montana, Vermont, Washington, West Virginia.

And then I responded:

Subtracting those states and the ones that already participate in the CSP program leaves me with NV, AZ, WY, OK, IA, MO, MS, NH, RI, HI, AND AK.

So states from these states and only these states are eligible. Is that correct?

She said:

Eligible applicants from these states would be able to apply.

Notice the weasel words: she didn’t say that the states I listed were the actual and only ones eligible. So I sent back yet another note asking her to verify that and she replied “For the current competition, only eligible applicants from these states would be able to apply.”

Beautiful! Finally! After a half dozen or so e-mails, I extracted the crucial eligibility information. Based on her tenacious and expert obfuscation, she deserves to promoted, possibly to Undersecretary for Obscure RFP Development (isn’t it obvious that I’m only talking about the current competition, not every conceivable competition?).

Wouldn’t it have been easier if the initial RFP simply stated the eligible states? The obvious answer is “yes,” but it also wouldn’t leave room for potential mistakes from the Department of Education. Instead, the RFP eligibility is convoluted and hard to understand for reasons known chiefly to bureaucrats; when I asked Erin, she wrote, “The states are listed in that way to encourage eligible applicants whose states have an approved CSP grant to contact their state departments of education.” Maybe: but that reason smacks of being imagined after the fact, and the goal could’ve been more easily accomplished by just listing the 11 eligible states and then saying, “Everyone else, contact your SEA.” But the Department of Education has no incentive to make its applications easier for everyone else to understand—and it doesn’t.

When I wrote about Deconstructing the Question: How to Parse a Confused RFP and RFP Lunacy and Answering Repetitive or Impossible Questions, I was really writing about how needlessly hard it is to understand RFPs. This is another example of it, and why it’s important for grant writers to relax, take their time, and make sure they understand every aspect of what they’re reading. If you don’t, you shouldn’t hesitate to contact the funding organization when you’re flummoxed.

The material most people read most of the time, whether in newspapers, books, or blogs, is designed to be as easily comprehended as possible. Many things produced by bureaucracies, however, have other goals in mind—like laws, for example, which are designed to stymie clever lawyers rather than be understood by laymen. Such alternate goals and the processes leading to bad writing are in part explicated by Roger Shuy in Bureaucratic Language in Government & Business, a book I’ve referenced before and will no doubt mention again because it’s so useful for understanding how the system that produces RFPs like the one for the Charter Schools Program (CSP) Grants to Non-State Educational Agencies come about and why correspondence with people like Erin can be frustrating, especially for those not schooled in the art of assertiveness.* In grant writing, assertiveness is important because confused writing like the eligibility guidelines above is fairly common—like missing or broken links on state and federal websites. I recently tried finding information about grant awards made by the Administration for Children and Families, but the link was broken and the contact page has no e-mail addresses for technical problems. I sent an e-mail to their general address two weeks ago anyway and haven’t heard anything since.

Were it more important, I’d start making calls and moving up the food chain, but in this case it isn’t. Regardless, tenacity and patience are essential attributes for grant writers, who must be able to navigate the confused linguistic landscape of RFPs.

* Sorry for the long sentence, but I just dropped into a Proustian reverie brought on by RFPs instead of madeleines. Perhaps one of you readers can translate this long-winded sentence into French for me.

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Stuck on Stupid: Hiring Lobbyists to Chase Earmarks

A faithful Grant Writing Confidential reader and fellow grant writer, Katherine, sent an email wanting my take on a public agency hiring a lobbying firm to seek federal earmarks. For those not familiar with the term, it means getting a member of Congress to slip a favored local project into a bill, bypassing normal reviews and restrictions. The Seattle Times recently ran a nice article on the subject featuring our own Representative Jim McDermott, who is skilled at the art of earmarks. The only member of Congress I know doesn’t push earmarks is John McCain. For the rest of Congress, earmarks are a way of funneling money into often dubious projects, such as the infamous Bridge to Nowhere.

Back to the local school district where Katherine lives, which decided to hire a DC lobbying firm for $60K/year to get earmarks. She suspects this is a scam. I have no idea whether this particular lobbying firm is up to no good, but in my experience hiring lobbyists to chase earmarks will make the lobbyists happy and lead to lots of free lunches and dinners for public officials visiting DC to “confer” with their lobbyist and legislators, though it is unlikely to end with funding.

A small anecdote will demonstrate this phenomenon. About 20 years ago, when I was Development Manager for the City of Inglewood,* I was directed by the mayor via the city manager to contract with a particular DC lobbying firm to chase earmarks. Since the city manager and I knew this was likely a fool’s errand, we agreed to provide a token contract of $15K. I accompanied the mayor and a few others to DC for the requisite consultation with the firm. About 10 in morning, we strolled from the Mayflower Hotel over to K street, where all the lobbyists hang out, and were ushered into a huge conference room with a 25 foot long table.

Over the next two hours or so, just about every member of the firm wandered in to opine on potential earmarks. Around 12:30, we all repaired to an expensive DC restaurant (are there any other kind?) for steaks and cocktails. We had a fine meal and I met then former Vice President Walter Mondale, who had morphed into a lobbyist himself and was taking his clients out for lunch. When I got back to Inglewood, I received an invoice from our lobbyist which exceeded the contract amount. Our contract paid for less than one meeting in DC and resulted in no earmarks. But I had a great time, since it is always fun to visit DC using somebody else’s money.

That experience schooled me on earmarks and about why Inglewood had gone about acquiring them in the wrong way. If a public agency wants to try for an earmark, the agency can do so just by contacting the chief field deputy for Senator Foghorn Leghorn. Congressional field deputies know all there is to know about the earmark process. If your representative is in a mood to support your project (e.g., needs help to get re-elected and wants to say they are standing up for schools), they will fall all over themselves directing their staff to push the earmark. If they don’t want to for some reason, all the lobbyists in the world won’t force the issue. In that situation, the school district might just as well use the money to buy lotto tickets in hopes of funding the project, rather than hiring a lobbyist. Furthermore, going through the congressional field office will avoid the EDGAR problems described below.

Another problem is that if you have almost all of the 535 members of Congress promoting various earmarks, the chances of your particular project being included are pretty slim. This is another reason we don’t recommend pursuing earmarks. If Katherine’s school district really wants to fund education projects, this is not the way to go about it. Instead, they should hire an experienced grant writing firm, like Seliger + Associates, to help them refine and prioritize project concepts, conduct grant source research, and start submitting high quality, technically correct proposals. If the concepts have merit, they will eventually be funded. The Department of Education and others provide billions of dollars in actual grant funds every year. This is a larger, more reliable source of funding than earmarks.

Finally, if an organization is lobbying, it can end up closing off grant funds. The “Education Department General Administrative Regulations” (EDGARs) govern grants and contracts made through the Department of Education, and they’re designed to prevent corruption, kickbacks, and the like. Subpart F, Appendix A, deals with lobbying. It says:

The undersigned certifies, to the best of his or her knowledge and belief, that:
(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, to any person for influencing or attempting to influence an officer or employee of an agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.

And so on, which you can read if you’re a masochist. EDGAR basically means that an agency which pursues lobbying can end up screwing itself out of the much larger and more lucrative grant world.

Katherine has also found questionable math regarding the particular lobbyists’ probable efficiency, and the lobbyist also makes the dubious claim that it has a “90% success rate.” But what does “success” mean in this context? Does that mean 90% of clients get some money? If so, how much? And from who? And through which means? Seliger + Associates doesn’t keep “success” numbers for reasons explained in our FAQ. We constantly see grant writers touting their supposed success rate and know that whatever numbers they pitch are specious at best for the reasons described in the preceding link.

Public agencies hiring lobbyists for earmarks is often a case of being stuck on stupid.

* “Inglewood always up to no good,” as 2Pac and Dr. Dre say in California Love.

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The Danger Zone: Common RFP Traps

When first looking at a RFP, it is a good idea to remember Robbie the Robot from Lost in Space (the 60’s TV show, not the terrible movie remake) shouting “Danger Will Robinson,”* because when you open a RFP, you’re entering THE DANGER ZONE.

Those innocent looking RFPs are filled with traps. For example, if you are responding to a RFP that was previously issued and you have a proposal from a past submission, you will typically find that the funder has changed the RFP slightly, often in a subtle way. This might be by changing the order of questions, using different headers or outline patterns, requiring a specific font, and the like. Since such changes usually are not substantive, I assume that this is done to trap novice or lazy applicants who just copy the previous proposal and change the date. It may be that program officers are basically bored and have nothing better to do, so they find cheap thrills in this, like rabbits racing across the road in front of a car. So, even if you submitted the same project concept for the same program last year, make sure that you carefully go through the RFP to find these public sector equivalents of “easter eggs”. It’s also a good idea, of course, to update the data, polish your text, and find all those typos that slipped through the last editing process.

Another RFP trap is repetitive questions. It is not unusual to find the same question, more or less, asked several times. Whether this is an intentional trick or an artifact of committee members writing different RFP sections, they can be a real challenge for the grant writer, particularly if there are page limits. So, what to do? If there is room, simply rewrite the first answer over and over again. I know this results in a pretty boring read, but occasionally, such as with some HUD programs, reviewers may only read particular sections. The alternative, which we use when there are space limitations, is to refer back to the original answer (e.g., As noted above in Criterion 1, Section 6.a and Criterion 2, Section 2.c, Citizens for a Better Dubuque has extensive existing referral relationships with the full range of youth providers, which will be utilized to provide project participants with service beyond the project scope. Wow, what a great proposal sentence! Feel free to steal it.). However you handle the problem, never ignore questions, as this practice runs the risk of missing points or having the proposal declared technically deficient and not scored at all.

Sometimes, the RFP asks lots of obtuse questions, but never specifically explicitly asks what you plan to do or how you plan to do it. I know this seems incredible, but the Department of Education, for example, often has RFPs like this. In this case, pick any spot you like and insert the project description (e.g., Within the above context of how the Dubuque After School Enrichment Initiative is articulated with Iowa learning standards, the following describes how academic enrichment services will be delivered:). No, this is not a smiley face, just a colon followed by a closed parenthesis. If I was going to use an emoticon, it would have a frowney face to evoke reading RFPs.

One of my favorite RFP traps is to find different instructions for ordering responses in different parts of the RFP. For example, there may be a series of outlined questions, followed by a series of criteria that ask the same questions, more or less, but in a different order. Since, unlike Schrodinger’s cat, the proposal can only have one “state,” the grant writer has to pick one to follow. Before plunging into the writing, it’s not a bad idea to contact the program officer to raise this conundrum. Unfortunately, even if you are able to find the program officer, your question will usually be met with either giggles or a cold, “read the RFP, it’s all there.” In either case, you’re back to having to pick one of the two orders.

Finally be afraid, be very afraid of RFPs for newly minted programs. This is because the writers of RFPs for new programs usually have no idea what they want from applicants. We’ve been working, for example, on a $8 million proposal being submitted to a California state agency on behalf of a public sector client. The program is new and the RFP is a mess in terms of conflicting guidance, hidden requirements and so on. Since there were some aspects of the RFP that were beyond even our amazing deductive abilities, after leaving several messages over a week, we finally got the program officer on the phone. He sheepishly admitted that they had “forgotten” to include some of the instructions but planned to see what they got in responses and fix the RFP next year. It was good to find an honest man in Sacramento, and we put the submission package together in the most logical manner we could. Hopefully the state agency will straighten out the RFP next year.

We have seen our approach used in subsequent RFPs before, so this is not impossible. We wrote the first HUD YouthBuild proposal funded in Southern California in response to the first funding round in 1993. Not surprisingly, the Notice of Funding Availability (NOFA: HUD-speak for RFP), was a complete nightmare and we had to develop a response format more or less on our own, after a number of unproductive calls to HUD. Fortunately, when the next Youthbuild NOFA was issued, it bore a remarkable resemblance to our submission in terms of how the proposals were to be organized. It is always fun to drag the bureaucracy toward enlightenment, so matter how hard the slog. YouthBuild moved to the Department of Labor in FY 2007, and, yes we successfully made the transition by writing yet another funded YouthBuild proposal last year, bringing our total of funded YouthBuild proposals to a baker’s dozen or so, proving that the funding agency is largely irrelevant to the grant writing process.

* Robbie actually made his screen debut in the wonderful 1956 film Forbidden Planet.

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Bad Government English

I realize that I could collect examples of bad English from the Federal Register all day long and that doing so is as challenging as picking a fight with six-year-olds, but this sentence from the Department of Education’s Charter School Program stands out:

The purpose of the CSP is to increase national understanding of the charter school model and to expand the number of high-quality charter schools available to students across the Nation by providing financial assistance for the planning, program design, and initial implementation of charter schools, and to evaluate the effects of charter schools, including their effects on students, student academic achievement, staff, and parents.

Whew! For an extra challenge, diagram the sentence, with all its subordinate and nested clauses. Stanley Fish finds similar problems in an education report and sees bureaucrat speak as the problem:

In this case the bad writing takes two forms. First, there are the sentences made up of empty abstractions linked together in an awkward and strained syntax: “The goal is to magnetize lost talent and ensure that students thrive and progress, in order to create new generations of innovators who will enable New York State to continue as one of the world’s idea capitals.” And there are the sentences that actually say something, but in a prose so clotted and bureaucratic that it takes several readings to figure out what it is […]

A good description of many Requests for Proposals (RFPs)!

Posts such as this might become an occasional series, like the Bulwer-Lytton Fiction Contest, which is “a whimsical literary competition that challenges entrants to compose the opening sentence to the worst of all possible novels.” Sample loser/winner: “Detective Bart Lasiter was in his office studying the light from his one small window falling on his super burrito when the door swung open to reveal a woman whose body said you’ve had your last burrito for a while, whose face said angels did exist, and whose eyes said she could make you dig your own grave and lick the shovel clean.”

(And yes, the title of this post is intentional.)