Tag Archives: EDA

The federal budget in the age of Trump: Round up the usual suspects

The New York Times says that “Popular Domestic Programs Face Ax Under First Trump Budget.” Those listed include the Corporation for Public Broadcasting, Legal Services Corporation, AmeriCorps, National Endowment for the Arts (NEA), and National Endowment for the Humanities (NEH). With the exception of AmeriCorps, which wasn’t yet born, the rest are the usual suspects, which have been proposed for the chopping block on and off since David Stockman* was Director of the Office of Management and Budget in 1981. I’ve seen this movie before, and I’m highly confident that, after the Congressional inquisition is over, NEH, NEA and the rest will ride off from Capitol Hill like Keyser Söze at the end of The Usual Suspects.

You might be surprised to learn that Congress last passed an actual Federal budget in 1998! Since then, Congress has used a variety of legislative tricks to “pass” non-budget budgets, including Continuing Resolutions (CRs), department budget authorization bills, and budget reconciliation bills to enable senators and representatives to avoid going on the record voting for or against an actual budget. This whole mess is tied up with the headache-inducing need to pass a bill increasing the Federal debt limit every six months or so.

In March, we’ll get to experience this exercise in political theater again, as the Trump administration will likely propose a revised FY ’17 budget (not to be confused with FY ’18 budget coming along later in the year). As reported by the NYT and others, this revised budget will likely propose a decrease in FY ’17 budget authorizations for selected discretionary domestic Federal spending agencies/programs like NEA and its pals. This is opposed to the usual practice of “budget hawks” to propose reductions in the rate of increase in Federal spending, due to the Feds using baseline budgeting (another headache-inducing concept) rather than zero-based budgeting.

My guess is that few discretionary programs will receive actual cuts and none will be eliminated (see one of our most popular posts, “Zombie Funding—Six Tana Leaves for Life, Nine for Motion,” to learn how Federal programs usually return from the dead). That’s because every Federal discretionary funding/grant program has constituencies in every Congressional District—along with an army of lobbyists.

Let’s use NEA as an example. NEA funds symphonies, theater groups, art museums, etc., everywhere. These are nonprofits, the boards and docent corps of which are composed mostly of well-off locals, who might be married to Congresspeople or their donors. They’re likely to be members of the same country clubs, churches/synagogues, and Chambers of Commerce as Congresspeople. That means Congressman Horsefeathers is not only going to be beaten up by lobbyists and donors but is going to an earful at the breakfast table.

As a young grant writer during the Reagan ascendancy, I learned that—despite the fevered rhetoric you’re going to soon hear and the attempt of the Trump administration to cut something—most grant programs will squeeze through. In contemplating Federal budget cuts, I use the Economic Development Administration (EDA) as my yardstick. EDA, the most overtly political of Federal grant-making agencies, has been around since 1965. Every so often, an administration or Congress threatens this small nimble dinosaur with a budget meteor, but EDA always dodges. I won’t take the latest budget battle seriously until EDA dies. I won’t bring up the real budget brontosauruses like HUD and the Department of Education. They’ve survived Presidents Reagan and Bush the Younger, as well Speaker Newt.


* Stockman now shows up in infomercials hawking various doomsday economic books (or gold), but he actually wrote a terrific political autobiography, The Triumph of Politics: Why the Reagan Revolution Failed. I read this in the mid-80s and it’s relevant once more.

Federal Naming Conventions, EDA’s i6 Challenge, the Future of Innovation, and the Ministry of Silly Walks

Carefully study this screenshot of EDA’s website for the i6 Challenge:

Bear in mind that the purpose of the i6 program is “to support groundbreaking ideas in science and technology,” and ideally to fund really innovative stuff (in this respect it’s like i3 or any number of federal programs). But you might notice something funny about the screenshot: whoever designed the website either didn’t test it in Firefox or didn’t test it in Firefox for OS X. This is pretty funny, since Firefox is the web browser of choice for geeks and basically restarted the development of web browsers in general after Microsoft decided they’d won with Internet Explorer 6 and didn’t have to do anything anymore. And, as Paul Graham points out, lots of hackers are using Macs again.

In other words, lots of people at the forefront of technology are probably using the very tools that aren’t being tested for by a program designed to appeal to people at the forefront of technology.

The other funny thing about this program is the name, especially because we just had the the Investing in Innovation Fund (i3) program from the Department of Education, to which i6 is completely unrelated, despite sharing a similar name. It raises a number of questions, like whether there is any limit to the number of programs with “i” in them, whether those programs must be a multiple of 3, or why the letter “i” is so much more popular than its close siblings “h” and “j.” We’re also apparently missing i1 – i2 and i4 – i5, which is a bit like HUD’s Hope VI. What happened to the rest of the HOPE programs, like V?

Anyway, this mixture of numbers and faux acronyms and what not makes me think there should be a ministry of federal program names, related to the ministry of silly walks:

(Sample dialog: “I have a silly walk, and I’d like to obtain a government grant to help me develop it.”)

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.

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

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

The Grants.gov notifications says:

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

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

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

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

Assuming your EDR accepts the initial proposal:

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

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

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

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

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

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

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

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

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

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


 

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

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

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

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

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

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

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

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

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

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

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


 

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

It’s a Grant, Not a Gift: A Primer on Grants Management

I was in LA over Labor Day weekend and, at a pool party, chatted with a semi-retired CPA who has been hired by a large nonprofit hospital to help with an audit of a federal grant. The audit is being performed under the Office of Management and Budget (OMB) Circular No. A-133. OMB publishes a variety of circulars covering all sorts of topics. Some, such as A-133, are of great importance to nonprofit and public agency grant recipients but are routinely ignored (to the great peril of the agencies).

In the case of the LA hospital I discussed over daiquiris*, the organization was so surprised and elated at getting the grant that they treated it like a Christmas present. In other words, even though the hospital is a multi-million dollar operation with a full-fledged accounting department, they completely failed to follow federal accounting rules in implementing the grant. They spent the money more or less without regard to terms of the RFP and did not follow A-133 requirements. When faced with the prospect of an unsmiling federal audit team and an unflattering story in the LA Times, they brought in a knowledgeable CPA to straighten out the mess.

The issue resonates with me because, in addition to writing more proposals than I care to think about, I’ve also had the thankless task of managing numerous grants. My favorite story about grant management concerns a large Department of Energy project for electric cars during the late 1970s that I wrote when I worked for the City of Lynwood. This long-forgotten program gave the city about $1 million to buy and operate ten electric vehicles, which proved to be slow and unreliable, making them perfect for a municipal fleet. We were unlucky enough to be selected for an audit and I got tagged to handle it. The auditor turned out to be from the Department of Defense, since the newly created Department of Energy was too fresh to have its own auditors. I settled the fellow down in a conference room with donuts, an essential tool for all audits, and he asked his first question: “What product do you produce in this facility?” Since we were at City Hall, I smiled and responded: “Promises.” The audit went downhill from there.

Based on that experience and many others, here are some basic tips on managing grants:

  • If you don’t have a finance director familiar with grant accounting, find an outside accounting firm that is and hire them to set up your grant-related accounts and procedures.
  • Make sure the person responsible for managing the grant has obtained, read and understands the relevant regulations, including OMB Circulars for federal grants.
  • Spend the grant funds as quickly as you can, since funders don’t want the money back. If an agency fails to spend a grant and returns the funds, the funder will be very unlikely to award another grant.
  • Make sure the funds are spent in accordance with the grant agreement. It is important that the agency can show “maintenance of effort,” meaning that whatever was being done before is not being reduced following grant receipt and that the agency is not supplanting existing funds with grant funds. For example, if the grant is for after school programming, it is not okay to use the grant to pay for current after school programming so that the District Superintendent can remodel her office. If an audit disallows expenditures, the agency will have to pay the money back, which is not an attractive prospect.
  • Keep accurate records, including expenditures, personnel records, activities and in-kind support. That’s right, if you’ve included in-kind support as a match in the budget, you may have to prove that it was provided, so keeping track of volunteer hours, value of referral services provided, etc., is essential. Even innocent and detailed records can cause problems during an audit. For example, while serving as Development Manager for the City of Inglewood**, I had to handle an audit for an Economic Development Administration (EDA) grant. The grant involved demolition, which meant Davis-Bacon prevailing wage requirements for all persons paid through the grant. When the auditor began pulling expenditure records (for each expenditure, this means a check request, purchase order and cancelled check) for workers, it turned out that every demolition worker had the same address, which was a check cashing store. The contractor was apparently having the workers cash their checks and return a good portion of the so-called “prevailing wages” the workers were supposed to receive to the contractor. To avoid disallowance of costs, we had to chase down the contractor once we figured this out to get him to provide back pay to a whole bunch of suddenly very happy demolition workers.

The secret to grant management is to remember that everything related to a grant is likely public information, so don’t do anything you wouldn’t mind seeing on the front page of the local newspaper. As long as you think your grant-funded trip to Las Vegas will pass the smell test for having something to do with solving the challenges facing at-risk youth being funded by a Department of Education grant, I say, Viva Las Vegas!. Just keep in mind, that, when it comes to grants, what happens in Vegas may not stay in Vegas.


*I’m talking real Hemingway “Papa Doble” daiquiris, not the disgusting pre-made concoctions found in most bars.

** As Tupac said and as quoted previously, “Inglewood always up to no good.”