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What counts as an eligible service area for SAMHSA’s “Resiliency in Communities After Stress and Trauma” (ReCAST) program?

Long ago, we wrote about what grant writers and applicants should do when confronted by a poorly organized RFP; because little external pressure pushes federal agencies to write RFPs that make sense, one finds too many RFPs that leave a lot of questions. SAMHSA’s “Resiliency in Communities After Stress and Trauma” (ReCAST) Notice of Funding Opportunity (NOFO) is a case in point: eligible applicants are those “communities that have recently faced civil unrest, community violence, and/or collective trauma within the past 24 months.” Okay: the NOFO will surely get more specific, right? But the ReCAST NOFO says that “Community violence is defined as the exposure to intentional acts of interpersonal violence committed in public spaces by individuals who are not related to the victim.” Okay: but how much violence? Do two murders count? Do two instances of battery count? Almost every city of any size has likely experienced at least two “intentional acts of interpersonal violence” committed by strangers in the prior 24 months. So how much is enough? Is more better, for purposes of being funded by this program? How are applicants to judge the feasibility of being funded? Being able to have some sense of eligibility is key, because preparing and submitting a SAMHSA application isn’t a minor endeavor.

Then there is the issue of “collective trauma.” Do natural disasters count? I’ve read the definitions of “collective trauma” on pages 8 – 9 of the ReCAST NOFO, and I’ve gone through all 41 uses of the word “trauma,” but I don’t see an answer to that specific question. Natural disasters are violent and often cause injury and death, which makes me lean towards “yes,” but the emphasis on “civil unrest” seems to point to a very specific set of issues that SAMHSA has in mind.

So I sent an email to the SAMHSA contact person, Jennifer Treger, asking her a version of the above. She wrote back: “Thank you for your inquiry. Please refer back to the definition that you have pointed out on pages 8-9 of the funding opportunity. If you determine your community meets the eligibility based on the definitions, please feel free to submit an application.” But how am I, or anyone else, supposed to judge whether a specific community is eligible based on that vague definition? I tried asking her in another version, and she reiterated, unhelpfully, that “We can only respond to what is in the NOFO.”

She also wrote that: “You can determine if you feel your community meets the definition for Collective Trauma as stated in the NOFO.” But the problem is that how I “feel” doesn’t matter at all to SAMHSA in determining eligibility; only SAMHSA’s judgments matter (SAMHSA has the money). It’d be useful for SAMHSA to list, in its view, which communities have had sufficient “civil unrest, community violence, and/or collective trauma within the past 24 months” to qualify for ReCAST. Or, alternately, what metrics they’d use. An FBI Uniform Crime Rate (UCR) of x per 1,000 people, for example, would be a specific metric.

Too many federal agencies love the latitude that vagueness implies. It’s hard to advise our clients on whether they should apply to ReCAST without more specifics, but those specifics evidently aren’t going to be forthcoming. I guess we’ll have to try to look at our feelings and our client’s feelings, and hope SAMHSA feels what we feel.

For more on similar matters, see RFP Lunacy and Answering Repetitive or Impossible Questions: HRSA and Dental Health Edition.

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Making it Easy to Understand Who’s Eligible for HRSA’s School-Based Health Center Capital Program

The Affordable Care Act has made it especially hard to figure out who’s eligible for a program. This week, the “Affordable Care Act: Grants for School-Based Health Center Capital Program” is our star. The announcement says that eligible applicants must “Be a school-based health center or a sponsoring facility of a school-based health center as defined in 4101(a)(6) of the Affordable Care Act [. . .]”

Once you track that section down, however, you find this: “(6) DEFINITIONS- In this subsection, the terms ‘school-based health center’ and ‘sponsoring facility’ have the meanings given those terms in section 2110(c)(9) of the Social Security Act (42 U.S.C. 1397jj(c)(9)).” So it’s off to find the Social Security Act. Eventually you’ll find:

In general.—The term “school-based health center” means a health clinic that—

(i) is located in or near a school facility of a school district or board or of an Indian tribe or tribal organization;

(ii) is organized through school, community, and health provider relationships;

(iii) is administered by a sponsoring facility;

(iv) provides through health professionals primary health services to children in accordance with State and local law, including laws relating to licensure and certification; and

(v) satisfies such other requirements as a State may establish for the operation of such a clinic.

Note that these five subsections describe only what school-based health center means “In general.” What would a specific definition be? Notice too that the act doesn’t mention whether this program applies only to K-12 schools, or if universities count. We’re choosing to interpret Local Education Agencies (LEAs) and their subsidiaries as eligible, since IHEs aren’t mentioned and “school district” generally implies LEAs. If you have any reason to think otherwise, let us know in the comments.

This isn’t the first time we’ve investigated curious, obfuscatory eligibility requirements, and I doubt it will be the last.

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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 (http://edocket.access.gpo.gov/2008/E8-13470.htm). 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 http://www.ed.gov/programs/charter/index.html.

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.