Tag Archives: Department of Labor

First HRSA, Now DOL: Simpler Forms and Reasonable Templates in the FY ’16 YouthBuild FOA

A few weeks ago we noticed that “HRSA made it harder for NAP applicants to shoot themselves in the foot;” now it appears that DOL is getting in the game. In this year’s YouthBuild SGA, DOL includes a form called “WORKSHEET_weighted_average.xlsx,” which models what previous YouthBuild SGAs have only instructed applicants to do regarding unemployment rates. Years ago applicants could do pretty much whatever they wanted regarding unemployment rates, using any data sources, but over time DOL has gotten more and more specific, presumably so that they’re comparing homogeneous numbers.

Today, calculating weighted average unemployment rates isn’t hard, exactly, but we’d bet that DOL got all kinds of interesting, incompatible responses to these instructions, from the 2015 YouthBuild FOA:

The applicant must provide weighted average unemployment rate (rounded to one decimal place) of the combined cities or towns identified as part of the target community(ies) compared to the national unemployment rate as of the latest available comparable data. This data is broken into two youth age subsets: 16 – 19 and 20 – 24. Applicants will have to average the unemployment rate for these two age groups by adding the populations together and then dividing by the total population.

We know how to model this in Excel, but we shouldn’t have had to: DOL should’ve included a template long ago. Last year we wrote a post about how “Funders Could Provide Proposal Templates in Word,” and doing so would likely raise the quality of the average proposal submitted while simultaneously reducing the busy work of applicants. Funders aren’t incentivized to do this, save by the knowledge of what they’ll get if they don’t provide templates, and consequently they don’t.*

Still, there are downsides to the the DOL approach. Applicants must now collect and aggregate specific data points for all the zip codes they’re serving, rather than choosing a different geographical unit, like a city or county, that ordinary humans understand. Few people say, “I really love living in zip code 66666.” But they might say, “Austin is great!”

Those of us who’ve done data work on large numbers of zip codes know how irritating that can be. I’m thinking of a particular project I worked on a couple months ago that had dozens of zip codes in the target area, and I never could figure out how to really expedite the process via the Census’s powerful, yet maddeningly Byzantine, website. There was (and is) probably an efficient way of doing what I was doing, but I never figured it out. The Census website is hardly the first piece of software with fantastically sophisticated abilities that most users never learn because the learning curve itself is so steep.

Overall, though, the simple, included form in this year’s YouthBuild SGA will probably lead to better proposals. We’re a little sad to see it, though, because conforming to the form makes it harder for crafty grant writers like us to weave threads of cherry picked and obfuscated data into an elegant, but sometimes specious, needs assessment tapestry that is coin of our realm.


* Given the unstated role of signaling in proposals, which we write about at the link, funders might be incentivized to make the grant process harder, not easier.

Batch/cohort versus continuous training: A problem with no solution

Job training programs, education programs, and related programs can work in two basic modes: batch/cohort (we’ll call it “batch” for this purpose) and continuous. Batch training happens the way most conventional schools function: the academic year starts at a particular time—usually in September—and if you don’t show up by September 5, you have to wait until the next break in the academic calendar (which is usually around January). No matter how bad you want to start school, you have to wait until the next time you’re allowed to start.

The alternative is a continuous program, in which a given participant starts whenever she’s ready to start. Two people might start in September, five in October, another in November, and three in December. The person who starts in November probably can’t work or learn effectively with the two who start in September, however, because the two who start in September are too far ahead of the one who starts in November.

Neither of these approaches is necessarily right, and two federal programs illustrate the difference: YouthBuild versus Training to Work 2-Adult Reentry, both of which are conveniently funded by the Department of Labor.*

YouthBuild wants batch processing: usually one class starts every year, and training takes about nine months to complete. Training to Work 2, like many prisoner reentry and Workforce Investment Act (WIA) programs, wants continuous training: if an ex-offender is released in October, it’s important for reintegration purposes to start that person in October.

Batch processing is hard because people who think they want to participate in October lose interest by the time January rolls around. Continuous processing is hard because people tend not to have the sense of solidarity that comes with working in concert with others towards a specific goal.

One problem with many Workforce Investment Act (WIA) programs, going back to WIA’s inception in the mid-80s, is that they’re drop-in, drop-out programs; no one develops a sense of team. Following intake and assessment at a WIA American Jobs Center (AJC), the client is usually referred to to a vocational training vendor. The training usually is starts immediately but may not be continuous, and the trainee may not be part of a training batch.

It may seem to the trainee that they’re actually not building towards anything concrete, as she lacks a cohort to share training outcomes with. Cohort issues are powerful: Even with semesters at a university, for example, many people still find the university experience alienating, especially coming from relatively small high school communities. To some extent living in dorms provides community; so can sports, or the Greek system (despite the problems with the Greek system).

The military puts every recruit through basic training in a batch, in large part to build some sense of team identity or “unit cohesion,” as this often referred to in the military. The cliché goes that guys on the ground don’t charge the enemy for their country or glory or the girl back home; they charge for the guys around them. Building a cooperative unit out of individuals is inherently hard and the many federal job training efforts don’t always work to build cooperative units. Repeated interactions build knowledge and to some extent happiness. It also builds cooperation, as numerous iterations of prisoners dilemma, divide-the-money, and similar game-theory games.

In WIA-land, however almost all programs work on a continuous-entry, continuous-exit model in which any individual is on his (usually) own. Most WIA vendors are in the meantime operating off-the-shelf training programs. These programs can be better-run or worse-run, but they do get people started quickly. In this sense they aren’t doing as much cherry-picking as batch programs, which require more patience. But because they require more patience, they may get better outcomes due to selection biases.

When YouthBuild was first released, HUD (which ran YouthBuild at the time) didn’t require batch training. But HUD changed the second YouthBuild NOFA to reflect the very first YouthBuild proposal we’d ever written (I was about 10 at the time, so my contribution was limited), because Isaac had been involved in job training proposal writing for years and knew that batch training would be easier for YouthBuild trainees and grantees. HUD read our proposal—we wrote some of the fist funded YouthBuild grants—and realized that our approach was a winner. We like to think we had an important contribution to the way in which YouthBuild operates its training, though almost no one knows this.

We can’t tell you the right approach for your program. But we can tell you that you should be thinking about the trade-offs involved in either approach, and you should be closely reading RFPs so you can divine whether the funder already prefers one approach or the other.


* And Training to Work is on our mind because the Training to Work 3 – Adult Reentry FOA was just released.

The Department of Labor’s “American Apprenticeship Initiative” (AAI) Shows Some Forward Thinking by the Feds

We’re interested in the Department of Labor’s “American Apprenticeship Initiative” (AAI) because it uses a word that rarely appears in the education media, federal grants, or foundation priorities: “apprenticeship.”

Apprenticeship has the ring of an out-of-circulation word, like “aesthete” or “monocle.”* Apprenticeships were common until the 20th Century, when either formal education or industrial blue-collar manufacturing jobs largely replaced them in the United States. But the number of manufacturing jobs has been declining for decades—and those that remain tend to require advanced skills—which has left formal education as the primary way we, as a society, take people aged 13 and up and try to turn them into productive—in the economic sense—adults.

The problem, however, is that a lot of people are poorly suited to sitting still and quietly for long periods of time while conducting abstract symbol manipulation. I’ve written about this issue before, in “Taking Apprenticeships Seriously: The need for alternate paths,” and a rare media account that discusses apprenticeship appeared in The Atlantic: “Why Germany Is So Much Better at Training Its Workers.” Apprenticeships haven’t gotten the attention they deserves. College dropout rates remain stubbornly high, and the solution favored by the feds is better college preparation and more wraparound supportive services in college (we discussed this in “Department of Education Grants Are All About Going to College and Completing A Four-Year Degree“). So far that hasn’t worked out well.

I’ve got an unusual perspective on formal education and college because in grad school I taught freshmen at the University of Arizona. The experience was educational for me for many reasons, one being that many if not most students seemed to have no idea about why they were in college or what precisely they were supposed to do there. Many didn’t particularly like being in classrooms, and it showed. Not surprisingly, only something like half of U of A freshmen complete a degree with six years. Students who don’t complete degrees get saddled with enormous debts and no degrees to show for it.

Not everyone is well-suited to the college environment, and that isn’t me being an elitist jerk. It’s an observation that should be obvious to everyone who has taught at a non-elite college. We—again, as a society—should have a viable system for training people who don’t like abstract symbol manipulation. They can learn and do useful things. I’m well-suited to abstract symbol manipulation—that’s my entire job—but I can acknowledge that many people aren’t.

The apprenticeship model and the university model should have porous borders—people who realize they don’t want to be apprentices should be able to pursue university education, and those in universities who realize they’d rather become electricians should be able to do that. Right now, however, public policy is oriented almost entirely towards the university model, to the detriment of many of those who don’t fit the model. We’re pleased to see the AAI as being an exception to the general principle.


* Though graduate school is still conducted largely in the apprenticeship model, which is sometimes acknowledged, since in a way no one really knows how to teach research or writing—they’re both taste-based skills, which makes them inherently difficult to teach.

A Report from the Front: Close Reading This Year’s DOL YouthBuild Solicitation for Grant Applications (SGA)

We wrote the very first funded YouthBuild grant for a Southern California client in 1994 and have written funded YouthBuild proposals for virtually every funding round since, which means that we have an unusually nuanced perspective on changes over time.* We’ve noticed two big changes and one minor change in this year’s SGA: market labor market information (LMI) data is out, green construction skills training is out, and the SGA is less structured.

Why?

First, LMI data has been a prominent feature of every YouthBuild SGA since the program was transferred from HUD to DOL about ten years ago. Applicants were supposed to demonstrate that construction skills were in high demand in their area, usually using phantom data, since the LMI data provided by states—the only source for such info—lags the real market by at least a couple years.

Those of you who have been alive and reading any news in the period from 2009 – 2013 know that Bad Things happened to the housing market. Household formation dropped like my Manhattan off a rooftop bar,** housing prices plummeted, and developers stopped building new housing or rehabilitating existing housing. Some went bankrupt. Today’s labor market data probably indicates that there is little support for the need for more construction workers. Requiring data that won’t support need anywhere makes YouthBuild as a program look stupid, and as all political observers know the ideal way to avoid information that makes you look stupid is to pretend it doesn’t exist.

LMI data has always been dubious because no one has a crystal ball; macro data doesn’t tell you much. Forward projections rarely work, and as Nassim Taleb points out (in colorful language) in The Black Swan, no one knows what’s going to happen in markets, labor or otherwise. It’s inherently not possible to know.

Jobs are growing at the low end (in healthcare, service, etc.) and, to a lesser but real extent, the very high end (technology, engineering). But no one can really take a large number of low-income high school dropouts and get them ready to work for Facebook or build the next WhatsApp. Entry-level jobs in fast food or caring for old folks, however, don’t demand a lot of training.

Secondly, green construction training is missing. Training for so called “green jobs” and “green construction skills” first appeared in YouthBuild SGAs about five or six years ago, more or less corresponding with the start of the Obama administration and the Stimulus Bill. As best we can tell, nobody’s talking about green jobs after the A123 Battery debacle and the like, and “green jobs” were never well-defined; “green practices” make more sense, but they really mean energy efficiency, which has been around since the energy shocks of the mid 1970s: double or triple-paned windows, high-efficiency appliances, and perhaps most importantly multi-family housing.

As Edward Glaeser points out in Triumph of the City, multi-family housing is by far the greenest way to live by all sorts of metrics. I’m living in New York on the 22nd floor of an apartment building; because New York’s density means that public transportation works, I don’t own a car. No one lives a greener lifestyle than me (I enjoy patting myself on the back).

To tie points one and two together, I’ll note that Isaac lives in Downtown Santa Monica, where many new multifamily buildings are going up. He got to talking to a foreman on one of the projects, and the foreman said that the buildings aren’t even really built on-site anymore: components come in larger and larger pieces, and then they’re assembled like Tinker Toys. The real greening of those building isn’t happening on-site; it’s happening in distant factories. And these buildings just don’t require as many people to build because so much is done off-site.

In much of the U.S., the real need for housing choice and affordable housing starts at the regulatory level, not the worker level. Matt Yglesias’s The Rent is Too Damn High observes that, in many places, permitting and local development rules hold back affordable housing because they restrict supply in the face of growing demand. New York and Seattle need to be able to create new housing before they need more construction workers. The Federal government has limited control over local land-use practices.

Finally, the SGA’s narrative section is less structured than it used to be. This is mostly a grant wave. Any program narrative can be more structured or less structured. The more structured program narratives will say things like “2. Program Design” then “a. Education and Occupational Skills Training” and then “Factor one: The evidence that the type of academic instruction offered…” Less structured program narratives will say things like, “What’re you going to do once you get all those damn kids in a room?” and let the applicant bloviate as long or as short as the applicant wishes.

We tend to like the latter version better, both because it’s more fun to write and because the resulting proposal tends to be more fun to read. Funders, however, can’t resist meddling and directing, so they tend to like to tell applicants what to do.


* If I live long enough maybe I’ll write the very last YouthBuild funded grant application.

** It was an accident.

FY ’15 YouthBuild SGA Issued by the DOL As Predicted—But With A Twist

Faithful readers will know that we recently predicted that the Department of Labor (DOL) would soon issue the FY ’15 YouthBuild SGA. The SGA was in fact published February 18. I still don’t know why DOL feels like it has to keep upcoming SGAs secret, unless it’s to make sure that their own staffers don’t have to meet deadlines, but at least they provided about 60 days to respond: the deadline is April 22. $73 million is up for grabs.

While the SGA publication was not much of a surprise, there is an interesting nugget (or “nougat,” as we like to call unusual aspects of RFPs*) in this one with respect to the slice and dice of available funds:

The Department intends to use up to 30 percent of the total available funding for this competition for the award of grants to eligible applicants that have not previously received a DOL YouthBuild grant or have not substantially completed performance on their initial DOL-funded grant award. [. . .] The remainder of [the] funds will be used to award grants to eligible applicants that have been previously funded by the DOL YouthBuild program and have demonstrated success in the program.

There are actually two pots of YouthBuild funds: $51,100,00 or $21,900,000, depending on the type of applicant. This is either good or bad news, based on how you like to handicap your agency’s likelihood of being funded.

Since we’re grant writers, not fortune tellers or racetrack touts, Seliger + Associates does not think much of this sort of handicapping. Our advice when asked this question—which generally happens several times a week—is simple: “If your agency is eligible and you want to run the grant program, apply. You can’t win the Lotto without buying it ticket.”

The above funding split mean that pretty much any otherwise eligible nonprofit or public agency can apply this year,** which is great.


* One other oddity: the SGA says nothing about green jobs, which the DOL has been hammering into applicants’s heads for the last half decade.

** If you read the above SGA quote carefully, you’ll note that the ineligible agencies are the previous YouthBuild grantees that screwed up their grants, somehow, at least in the eyes of the DOL.

Youth CareerConnect Program: The Department of Labor Provides An Early Holiday Present

The holidays come early year with this tasty new* program from the elves at the Department of Labor (DOL) Employment and Training Administration (ETA): the Youth CareerConnect Program.** There’s $100,000,000 up for grabs, with 25 to 40 grants to be awarded—in other words, serious money. Sequestration hasn’t been a horror story for nonprofit and public agencies—the federal trough is full and there’s always for one more nonprofit snout.

Read the RFP. You’ll realize you’ve seen this movie before—but just because the plot is stale doesn’t mean you shouldn’t see yet another version of boy meets girl. Youth CareerConnect funds small learning communities, career-focused curricula, employee partnerships, high school diplomas or equivalents, industry-recognized credentials, work readiness, low-income participants (including females and minorities), and (wait for it), wraparound supportive services. It’s like YouthBuild but without the construction training, or like prisoner reentry without prisoners, or community colleges without the community college.

The services may elicit a yawn but the money won’t. If your agency runs YouthBuild or almost any other training or supportive services for at-risk youth or young adults, this is a wonderful grant opportunity that could be run by almost any youth services nonprofit. Remember, though, that you should get going before your Thanksgivukkah turkey and latkes put you to sleep, because the deadline is January 27. All I can say to my pals at DOL ETA, is Gobbletov!

EDIT: As I noted in “Are You Experienced? Face Forward—Serving Juvenile Offenders SGA: A New Department of Labor Program That Mirrors YouthBuild,” it’s almost always a good idea to apply for the first funding round of a new program. The reasons are too many and varied to repeat here, but the original post is worth reading carefully for anyone debating about whether their agency should apply.

In addition, it’s worth noting that page 16 of the Youth CareerConnect SGA forbids community colleges from applying. That’s curious, because community colleges are probably the most plausible candidates for running YCC programs. They’re probably excluded because community colleges are the only eligible applicants for the Trade Adjustment Assistance Community College and Career Training (TAACCCT) Grant Program, which is essentially the same thing as YCC, except that it has even more money available. DOL just wants to spread the wealth to other organizations.


* It’s “new” in the sense that the title is new and the hundred million has been freshly allocated, but anyone who has ever provided job training services should recognize the melody, beat, and lyrics.

** I particularly like the way DOL has run Career and Connect together to form an allusion of speed and urgency with CareerConnect.

You Don’t Forget Your First RFP Amendment Post: DOL’s Face Forward Expands Eligibility Requirements

I got my first federal RFP amended last week.

It’s a bit like being blooded when you’re in the Mafia: the tenth time is just standard procedure, but the first time is special.* Isaac, for instance, has gotten numerous RFPs amended, which is always fun because our clients are amazed by our wizardly abilities.

The original version of DOL’s Face Forward Serving Juvenile Offenders Grants SGA said this about the eligible service population:

An individual may participate in a project funded under these grants if he/she: is between the ages of 16 and 24 on the date of enrollment [. . . and ] has never been involved with the adult Federal, state or local criminal justice system.

That’s a big problem for a lot of applicants: in New York and North Carolina, youth ages 16 and up are no longer considered juveniles and are therefore adjudicated by the adult justice system.** The original SGA also states that participants must be “currently involved or has been involved in the juvenile justice system or is currently a candidate for diversion under state guidelines for juvenile diversion Programs.” In most states, 16- and 17-year-old youth would be adjudicated within the juvenile justice system for minor crimes, but that’s not true in all states.

Even if a New York nonprofit identifies youth who were adjudicated by the juvenile justice system prior to age 16, most of those youth are likely to have also been involved in the adult system. Few at-risk youth give up criminal behavior at age 16 without supportive services. This is of course the whole point of Face Forward.

As a result, the original rules would make most New York and North Carolina nonprofits effectively ineligible for Face Forward, because they won’t be able to get enough mandatory participants.

I called and sent an e-mail to Mamie Brown (the Face Forward contact person) outlining the problem. She didn’t return my call but did send back an e-mail that completely ignored the point I described above, and she helpfully said, “Please review the Eligibility Requirements in Section III. 3 a) Eligible Participants of the SGA which clearly states who can participate and receive services under this grant. For your convenience the SGA specifically states [. . . ]”

Yes, thank you, I can read.

Whenever a contact person does this, it’s time to look for decisions makers or (unlike most Program Officers) at least a thinking human being. We decided to shoot for either an undersecretary in the DOL, or, since Face Forward is officially being offered by the Employment Training Administration, we decided to try for Assistant Secretary Jane Oates.

There are two dangers in this kind of bureaucratic wasp-nest poking: getting someone too low on the totem pole, who won’t make any decisions (that’s Mamie) or someone too high, who has no idea what the hell is going on in the bowels of the organization and will often be unwilling to respond until the lower echelons have been exhausted.

Sometimes it’s a good idea to jump straight to the top, but in this case we decided an intermediate person. If the intermediate person hadn’t been helpful, we would at least have her name and correspondence when we went further up the chain.

Anyway, I called Oates and left a message, then sent an e-mail. She was quiet for a few days, which is reasonable and not uncommon: she has to figure out what’s going on herself and formulate a response. But the deadline was approaching, so I also called and wrote New York Senator Chuck Schumer’s office. Senators and House members sometimes become involved in grant program rules if they think their home states aren’t getting a fair shot at the money.

Why? Because Senators and House members love to crow about all the money “they” got for their states and districts. We’ve actually had clients whose first notification of grant award came not from the federal agency, but from reporters calling because a Senator put out a press release about how he got more money for the state. Never mind that he had no bearing on the proposal and that letters from Congresspeople are worthless to applicants: the only thing Congresspeople love more than credit for getting money is money itself.

I don’t know if the person I found at Schumer’s office actually did anything, but a couple days after I contacted them Face Forward Amendment One appeared. The amendment changed “has never been involved with the adult Federal, state or local criminal justice system; and has never been convicted of a sexual offense other than prostitution” to “has never been convicted within the adult Federal, state or local criminal justice system; and has never been convicted of a sexual offense other than prostitution.”

That works for us. The new criteria makes it easier for our Face Forward clients to recruit eligible participants. Plus, in the real world of providing human services, most nonprofits are going to interpret plea bargains for minor crimes in the adult system as not being convictions—but rather, only being “involvement.”

I even got a nice e-mail from Eric Luetkenhaus, the DOL Grant Officer/Chief, about the amendment. When I wrote back to him and Oates saying to say thanks, I received an even more unusual e-mail from Oates: “Thanks to Eric and his team for fixing this but most of all Jake thanks for bringing this to our attention.” Wow! Usually, federal agencies hate issuing amendments, and we’ve never gotten an attaboy from a federal office before. Being as writers who are either a) well-versed in Federal matters or b) cynics (you decide), we were pleasantly shocked.

This story contains a recipe for how to get RFPs amended. If you want to try, you have to start by making sure there’s something wrong or contradictory in an RFP. If the RFP is okay, you obviously don’t need to amend it. Once you’ve determined that there’s a real problem, however, here’s a guide for public RFPs:

1. Start by calling and e-mailing the program contact. These days, most listed contacts don’t like to answer their phones and actually interact with the grimy, ugly public, members of which tend to do annoying things like ask follow-up questions. Consequently, they’ll probably ignore your calls, and you’ll need to send an e-mail. That’s what I did in this case, and I got the language of the RFP spit back to me by Mamie. First contact is unlikely to generate a useful response: the safest thing for a program officer to do is repeat back the language of the RFP. Consequently, that’s what they’ll almost always do (this is also why bidders’ conferences are generally useless for anything other than schmoozing).

2. Be reasonable. Most program officers face the public, and, while most of the public is reasonable, one crazy person can take a disproportionate amount of time and energy. Your goal is to come across as thoroughly reasonable as possible. If you’re not a good writer, find someone in your organization who is, and get them to write the e-mail. Be sure to directly quote from the RFP sections that concern you. Your freshman English teacher was right: quotation really is better and stronger than paraphrase.***

3. Get a response from the underling. This will show the decision maker you eventually reach that you’ve done your homework and, again, that you’re reasonable. Almost all contact people will behave like Mamie.

4. Be polite, but firm and specific. The “polite” part is key, again, because you can’t actually make a federal bureaucrat do anything they don’t want to do. You need to make sure that you’re perceived as reasonable. If you’re not, you’ll get justifiably binned as a loony. But you should also be firm: you want a change to be made for reasons X, Y, and Z.

5. If that doesn’t work, or doesn’t work expeditiously, try calling and writing your Congressperson or Senator. Some will be indifferent, but you should try to find the field officer or field deputy who deals with the federal agency that issued the RFP. The first person you talk to won’t be a decision-maker; their job will be to screen lunatics and to route constituents. You want to be routed to the right person, and frequently you won’t know who that is before you start. Again, your goal is to be scrupulously polite and reasonable, because the public-facing parts of the Congressperson’s office is designed to weed out lunatics.

Taken together, these steps won’t actually take much time, and they should yield results. But they won’t always. If they don’t, don’t yell and scream and holler. Back down and go back to whatever you’d normally be doing. The minute you start screaming, you’ve probably lost. If you get to the top bureaucrat, you’re probably stuck, and probably stuck permanently. But more often than not, genuine mistakes will be rectified—provided you know how to push effectively.


* Although I don’t have guys named Jimmy Caprese and Big Pussy congratulating me.

** As Judith Levine notes in Harmful to Minors: The Perils of Protecting Children from Sex: “One striking pair of contradictory trends: as we raise the age of consent for sex, we lower the age at which a wrongdoing child may be tried and sentenced as an adult criminal. Both, needless to say, are ‘in the best interests’ of the child and society.” We want teenagers to be adults when they commit crimes and “children” when they have sex, which tells you more about our culture than about teenagers.

And, as Laurie Schaffner points out in a separate essay collection, “[…] in certain jurisdictions, young people may not purchase alcohol until their twenty-first birthday, or may be vulnerable plaintiffs in a statutory rape case at 17 years of age, yet may be sentenced to death for crimes committed at age 15 [….]”

Laws, including those embodied in Face Forward, reflect race and gender norms: white girls are the primary target of age-of-consent laws, while African American youth are the target of laws around crime and delinquency. The contradictory trends are readily explained by something rather unpleasant in society.

*** Having taught freshmen English to hundreds of students, I know well the skepticism they feel when I tell them about the powers of quotation.

Are You Experienced? Face Forward—Serving Juvenile Offenders SGA: A New Department of Labor Program That Mirrors YouthBuild

Despite all the teeth gnashing and flailing of arms over the recent sequestration non-calamity, the Department of Labor has found $26,000,000 to issue an SGA (DOL-speak for “RFP”) announicng an entirely new program: Face Forward-Serving Juvenile Offenders, with grants up to a million dollars. In the face of all this squawking, honking and flapping of wings over the budget, DOL has birthed an entirely new grant program. As a grant writer, I’m kvelling like I would be from seeing a grandchild from one of my kids. Even better, this bouncing baby grant program is almost a dead ringer for its teen sibling and our favorite DOL program, YouthBuild. Why? Because:

  • The target population is at-risk youth ages 16 – 24.
  • It mandates basic skills instruction leading to a GED.
  • It mandates job training services, leading to an “industry-recognized” credential, whatever that is. But—and this is a big butt—you don’t have to focus on construction training, which makes the job training piece much easier to conceptualize and implement.
  • It mandates case-managed wraparound supportive services—including mentoring, “Individual Career Plans” (ICPs), leadership development activities, and so on.

As Jimi Hendrix sang, “Are You Experienced?” If the above sounds familiar, you are experienced with YouthBuild and a myriad of other job training programs for at-risk youth and young adults. While Face Forward applicants have to propose serving at-risk youth and young adults that have been or are being adjudicated in the juvenile justice system, many prospective YouthBuild clients meet the Face Forward eligibility criteria.

If your agency is a current or former YouthBuild grantee, you’re probably a great applicant for Face Forward—you already have the organizational outreach, partnership and case management infrastructure in place, as well as a documented record of success at engaging and training at-risk youth and young adults.

Even better is the fact that Face Forward is a new program. It’s always a good idea to apply for a grant program in its first first funding round if you’re even vaguely eligible. The opportunity simply doesn’t come along very often, and when it does, you should go for it. You shouldn’t wait around for new grant programs—as we said, there aren’t that many. We wrote a funded YouthBuild proposal for an LA area client almost 20 years ago, during the very first YouthBuild funding round, and the agency continues to be a strong YouthBuild provider to this day. Essentially, YouthBuild has become a grant annuity for this nonprofit.

During the first funding cycle, there are no former or grantees to compete against, and the funding source has no idea what a good proposal is supposed to look like. In this case, DOL seems to be clueless that they’ve accidentally cloned YouthBuild, so it should be possible to throw your old YouthBuild proposal into the proposal blender and pour out a more or less compelling Face Forward proposal.

If you don’t know how to do this without letting DOL know what you’re up to, call us and we’ll do the mixing and baking. Here is an important caveat, however: do not say that your Face Forward proposal copies the methodology in your YouthBuild program. This will make DOL feel sad and ordinary. Instead, tout how innovative and unique your approach is, even if it’s the same old same old. The DOL Face Forward staffers want to think they’re your only girlfriend. Don’t disabuse them of this quaint notion. You want them batting their eyes and fanning themselves furiously as they read your proposal. Think of this as grant writing foreplay.

Now, back around to the SGA,which contains this wonderful nugget: applicants have to partner with “American Job Centers (AJC), formerly One-Stop Career Centers or Local Workforce Investment Boards.” As an American, I feel better that we’ve tossed out the obnoxious One-Stop Career Center name and replaced it with the much more sonorous name: AJC (I can already imagine an aria about it).

This raises the question as to whether there is a federal office somewhere that specializes in changing program names for no apparent reason. Since I’m old as mud, I’ve seen federal job training programs morph from Comprehensive Employment and Training Act (CETA) in 1973 to Job Training Partnership Act (JTPA) in 1982 to the Workforce Investment Act (WIA) in 1998. To paraphrase The Who, in “Won’t Get Fooled Again,” “meet the new boss, same as the old boss.” There is nothing new in Face Forward. But you’re not going to say that in your proposal.

DOL Issues FY ’13 YouthBuild SGA—If You’re A Current Grantee, Here’s How to Beat the Eligibility Restriction

The Department of Labor just issued the FY ’13 YouthBuild SGA (“Solicitation for Grant Applications,” which is DOL-speak for RFP), and $75,000,000 is available with 75 grants! We’ve written at least 20 funded YouthBuild proposals over the years, including two in the last funding round, so we’re more than a little familiar with this program, which is one of the best ways of funding job training for youth and young adults. DOL, however, has the following wrinkle stashed in the SGA, which is designed to prevent an agency that received a FY ’12 YouthBuild from applying this year:

An organization (based on its Employer Identification Number), may only be awarded one grant as a result of this competition. This requirement applies to both new applicants and previously funded applicants that have received a DOL YouthBuild grant in a previous competition. In addition, grantees who received funding from the Fiscal Year (FY) 2012 YouthBuild competition [SGA/DFA PY 11-06] are funded through December 2015 and these grantees (based on its Employer Identification Number) are not eligible to participate in this competition.

You’re a hungry grant-seeking puppy and there’s all this YouthBuild baloney in the refrigerator. Here’s how to pry the door open and get your snout in the YouthBuild trough.

Note that the restriction applies to a grantee’s Employer Identification Number (EIN). Many nonprofits have an affiliated nonprofit with a separate EIN. For example, lots of churches are 501(c)(3) organizations that have separate 501(c)(3) organizations to operate human services programs or outreach ministries. In a case like this, you can have the non-YouthBuild grantee entity become the applicant and the grantee become the partner.

Similarly, if your organization received a FY ’12 YouthBuild and wants in on this year’s action—and who wouldn’t—you can find a local nonprofit or public agency you know and love to serve as the applicant, while once again your organization slips in the partner role.

As a partner, you can still receive a large subcontract to provide such services as outreach, participant selection, training and/or case management, or smaller role by providing technical assistance to the applicant for a fee. At a minimum, the applicant collects a tidy administrative rake and the stature of being a federal grantee, while the partnering entity keeps churning the YouthBuild dollars. In some ways, this is similar to the fiscal agent relationship used by nonprofits in formation that we’ve written about before.

One one way to sell DOL on the partnership concept in through a deft targeting maneuver. Say your organization, which is an FY ’12 grantee, primarily serves African American participants. Find an organization in your community that works mostly with Hispanics or Pacific Islanders to serve as the applicant. Voila, the funding argument becomes: Let’s bring the expertise gained in providing YouthBuild services to one vulnerable community to bear on another. Suddenly, you’re not a greedy agency, you’re a hero! Such is the magic of grant writing and the knowledge gained from writing proposals since dinosaurs walked the Earth.

I know the above works, because we’ve done it a few times. For example, about eight years ago we had a large nonprofit substance abuse treatment client in a Northeast state for which we had written several funded SAMHSA substance-abuse treatment proposals. Along came an unusual SAMHSA RFP to provide treatment services to college students—but only Institutions of Higher Education (IHE) were eligible applicants.

Based on our advice, our client formed a partnership with a local IHE that agreed to serve as the applicant and fiscal agent, while providing access to students who would be the target participants. In return, the proposal included a huge subcontract under which our client provided essentially all project services, while the IHE administered the grant.

SAHMSA bought the concept and the grant was funded for over a million dollars, and it was one of only 12 or so awards made. Our client received solid funding for five years and applicant received free outpatient substance abuse treatment services for its students. If this can work with SAMHSA, which is a reasonably sophisticated federal agency, it should be possible to slip-slide around the YouthBuild applicant eligibility issue.

Thoughts on the DOL YouthBuild 2012 SGA: Quirks, Lessons, and, as Always, Changes

YouthBuild season recently ended, at least for those of us lucky enough to be writing the proposals and preparing the application packages.

1. I’ve warned against the “Perils of Perfectionism” for grant writers, but it appears that RFP writers have also heeded this advice—too well. Page 23 of the original YouthBuild RFP* says, “These attachments will not count against the 15-page limitation for the Technical Proposal.” Page 26 says, “The chart and staffing plan should be included as Technical Proposal Attachments and do not count against the 15-page limitation of the Technical Proposal.” Yet the RFP says, in many other places, that the page limit for previous YouthBuild grantees is 20 pages and for new grantees it’s 25 pages. I sent an e-mail to Kia Mason, the contact person, and she (or he?) said, “Those are errors, the page limitation for previous YouthBuild applicants is 20 pages.”

Sweet!

There was another change that made sense: the original RFP requested that only county data be used in the needs assessment. A revision, however, allowed applicants to use city or other data. I imagine that the DOL got a lot of organizations saying things like, “We’re in L.A. county” or “We’re in Harris County,” along with 10 other organizations that will be forced to use the same data. And L.A. county contains everything from Beverly Hills to Compton to the city of Los Angeles itself.

2. I must give credit where it’s due: instead of playing hide-the-salami with data, as so many RFPs do,** YouthBuild this year simply told applicants where to find data and had applicants report uninterpreted data from a single source. This makes a huge, shocking amount of sense. I also suspect that the DOL got tired of the weird hodgepodge of data that they probably get from most applicants.

3. As long as we’re talking about data, I can also surmise that the DOL is implicitly encouraging applicants to massage data. For example, existing applicants have to report on the reports they’ve previously submitted to the DOL, and they get points for hitting various kinds of targets. In the “Placement in Education or Employment” target, “Applicants with placement rates of 89.51% or higher will receive 8 points for this subsection,” and for “Retention in Education or Employment,” Applicants with retention rates of 89.51% or higher will receive 8 points for this subsection.” Attaining these rates with a very difficult-to-reach population is, well, highly improbable.

That means a lot of previously funded applicants have also been. . . rather optimistic with their self-reported data. Still, those previously funded applicants’ haven’t necessarily been lying, per se. To understand why, let’s say that an organization is tracking a YouthBuild graduate and the organization finds that the graduate is working at McDonald’s. But she also worked on her Uncle’s deck for $30 last weekend. Is she employed? Is she employed in the construction industry? Or let’s say that a graduate reports that he’s enrolled in a community college. Do you call the community college and get the graduate to release his records, or do you take him at his word? Do you subtly encourage him to tell you he’s in school?

The cumulative weight of these micro decisions can have an enormous impact on the numbers that get submitted to the DOL. Some organizations are no doubt more diligent than others. We would never tell organizations to falsify data. But we do point out that not everyone interprets data claims the same way. The DOL implicitly rewards one kind of interpretation. Everyone knows there’s gambling at Rick’s in Casablanca. The official position is not always the right one, and it’s worth reading between the lines.

If you’re funded this year, you may want to remember this section when you’re filing your reports next year.

4. The RFP is structured in a strange way: the “Program Design” wants applicants to describe the training they’ll provide before the outreach, recruitment, and selection process. It would make more sense to structure the RFP in the order that participants will actually move through. Perhaps this is also symptomatic of the problems whoever wrote this RFP experienced in chopping up last year’s RFP to make this year’s.

5. The existence of YouthBuild is a testament to the power of zombie programs;*** graphs like the one in this post have proliferated and demonstrate that, not only is construction employment down, but it’s so far down that it’s at 1994’s level. This may be why the DOL will now let previously funded applicants offer alternative career paths. Still, training people in the construction industry right now doesn’t make a lot of sense, even by federal standards.

We also have pretty severe housing imbalances—there are too many housing units in places like Phoenix, Las Vegas, and the Inland Empire, and too few in places like Manhattan, Seattle, and San Francisco. The problem with the latter municipalities isn’t a matter of construction workers—it’s mostly a problem of municipal regulation, especially regarding height, density, and parking requirements. For more on this, see Edward Glaeser’s Triumph of the City, Matt Yglesias’s The Rent Is Too Damn High, Ryan Avent’s The Gated City, and Tom Vanderbilt’s Traffic. None of them will particularly help you write a YouthBuild proposal, but they will help you understand what’s going on.

6. Don’t be afraid of tautologies. You were warned against tautologies by your logic and writing teachers for a good reason, but you should disregard those warnings for a program like YouthBuild. There were a depressing number of questions like this one: “The applicant has an effective strategy to integrate all program elements, including the integration of community service and leadership activities supporting career exploration and occupational skill training.” The obvious answer—the program elements will be integrated by providing them together, rather than “in pieces”—is basically another way of saying, “Program elements will be integrated by being integrated.” Again: this doesn’t make a lot of sense, even by federal standards. The proposal can only be 20 or 25 pages, which doesn’t leave a lot of room for the repetition that DOL implicitly wants.

7. In keeping with the above, as usual, it was impossible to fully answer all the questions in 20 or 25 pages.

8. Page three of the RFP says: “Cost-Per-Participant: Cost-per-participant must fall in the range of $15,000 – 18,000 and the applicant must indicate the projected enrollment per year. The cost per participant should take into consideration the projected enrollment, leveraged funds and other resources supporting the program” (emphasis added). I wrote this to Kia Mason:

What does “take into consideration” mean in this context? Does that mean that YouthBuild wants a cost-per-participant that counts the entire match? For example, if an applicant requests $1,100,000 and gets the mandatory 25% of $275,000, the project total will be $1,375,000. Dividing that amount by $18,000 yields about 76, while dividing $1,100,000 by $18,000 yields 61. The SGA doesn’t offer any examples or further guidance about what this means.

He or she replied: “The cost per participant is derived from the federal amount requested only.” I imagine Kia got a ton of questions on this issue, since the phrase “should take into consideration” is so vague. I also imagine that a fair number of applicants didn’t inquire into the meaning of the phrase, and, consequently, the DOL will get half the proposals with one assumption and half with another.

9. There’s a particularly inane question under Section 1. d. Factor five: “The benefit of the participation of youth in occupational skills training within the selected industry(ies) that will be derived to the community.” The major “benefits” that the community might derive are at best nebulous. And they’re about the same for all communities: having people in jobs instead of jails, creating nominal tax payers, providing nominal low-income housing, and so forth. These benefits don’t change much from California to Connecticut.


* The Department of Labor prefers the term “SGA,” or “Solicitation for Grant Applications,” rather than RFP; we generally use RFP on this blog, rather than further confusing matters by applying the alphabet soup of acronyms that various federal and non-federal agencies use to describe the various ways they emit documents that will ultimately lead to the distribution of money.

My favorite recent example of acronym fever comes from the ACF’s Transitional Living Program and Maternity Group Homes: “The Family and Youth Services Bureau (FYSB) is accepting applications for the Transitional Living Program (TLP) and for Maternity Group Homes (MGH) funding opportunity announcement (FOA). TLPs provide an alternative to involving RHY in the law enforcement, child welfare, mental health, and juvenile justice systems.” I wonder if ACF also wants BBQ ASAP.

** See “RFP Lunacy and Answering Repetitive or Impossible Questions” for still more discussion on this issue.

*** Our post “Déjà vu All Over Again—Vacant Houses and What Not to Do About Them” also discusses elements of housing policy and how governments respond to housing issues.