Tag Archives: FEMA

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

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

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


* Plus, complaining is sometimes satisfying.

December Links: Dubious Education Policies, FEMA, Writing, School Reform, Manufacturers, Quiet, Dan Savage, the Security Ratchet, and More!

* This is not an Onion story: “Florida’s plan to measure students by race riles education experts.”

* From an interview with Michael Bloomberg:

If every time you want to do something, they demand the final results, when you’re just sort of feeling your way and trying to evolve, it’s hard to govern. When we live in a world — in medicine, or in science, you go down a path and it turns out to be a dead end, you really made a contribution, because we know we don’t have to go down that path again. In the press, they call it failure. And so people are unwilling to innovate, unwilling to take risks in government.

Your nonprofit or public agency is subject to the same forces. Don’t be seduced by a program or RFP’s stated desire for innovation: in the vast majority of federal and state grant programs, the funding agency expects you to do exactly what everyone else is doing (remember: grant writing is about “thinking inside the box“). We’re not endorsing these perverse incentives, but we are noticing them. Our post “What to do When Research Indicates Your Approach is Unlikely to Succeed: Part I of a Case Study on the Community-Based Abstinence Education Program RFP” also discusses these issues.

* The Joy of Quiet, which I often seek and too little find.

* How manufacturers and community colleges are teaming up, German-style, to create high-paying factory jobs. Good! We’ve pretty clearly got a problem with the way we treat college education in the United States.

* SAMHSA finally discovers Grants.gov, about eight years late.

* Obama phones? That, at least, is what they’re called in the community.

* If “The Bipartisan Security Ratchet” doesn’t scare you, it should:

The United States government, under two opposed increasingly indistinguishable political parties, asserts the right to kill anyone on the face of the earth in the name of the War on Terror. It asserts the right to detain anyone on the face of the earth in the name of the War on Terror, and to do so based on undisclosed facts applied to undisclosed standards in undisclosed locations under undisclosed conditions for however long it wants, all without judicial review.

* Anti-poverty volunteer keeps profit from homeless New Jersey man’s house sale.

* A couple years ago, we almost worked for these guys, who are now, unfortunately, declaring bankruptcy. At the time we had too many other clients to accept their assignment.

* “Why school reform is impossible.” Maybe.

* “As we watch computing become a central part of the language of science, communication, and even the arts and humanities, we will realize that students need to learn to read and write code because — without that skill — they are left out of the future.

* “How American Health Care Killed My Father,” and what to do about it. Unfortunately, we haven’t done the things we should have done and should be doing, as discussed in the article.

* “Write My Essay, Please! These days, students can hire online companies to do all their coursework, from papers to final exams. Is this ethical, or even legal?” This supports Bryan Caplan’s theory that much of education is about signaling.

* It was only a matter of time: Tuition by Major.

* “You Should Repeatedly Read Cochrane’s ‘After the ACA.’

* “Dan Savage: The Gay Man Who Teaches Straight People How to Have Sex.”

* “Another ex-chairman rebuffs CalOptima’s demand for money” shows how corruption can work in nonprofits; the more interesting question is why and how the story ended up in The Orange County Register. That story can often be as interesting as the corruption story itself, but it isn’t told here.

* “Overall, I am for betting because I am against bullshit. Bullshit is polluting our discourse and drowning the facts. A bet costs the bullshitter more than the non-bullshitter so the willingness to bet signals honest belief.” That’s from Tyler Cowen, “A Bet is a Tax on Bullshit.”

* The FEMA office in Jersey City was closed because of the storm.

* Ian McEwan: “Some Notes on the Novella.” Wow. Sample: “How often one reads a contemporary full-length novel and thinks quietly, mutinously, that it would have worked out better at half or a third the length. I suspect that many novelists clock up sixty thousand words after a year’s work and believe (wearily, perhaps) that they are only half way there. They are slaves to the giant, instead of masters of the form.” Yes.

Grants.gov and deadline goofs

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

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

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

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

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

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

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

Blast Bureaucrats for Inept Interpretations of Federal Regulations*

Jake received an email response to “FEMA and Grants.gov Together at Last” from a firefighter who is working on a Assistance to Firefighters (AFG) proposal who seems to have been given a bum steer by AFG Program Officer and Jake’s nemesis, Tom Harrington (for background, see “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats” and the hilarious e-mail exchange with Mr. Harrington). According to our email correspondent, Mr. Harrington, the AFG contact person, said that vendors can’t help fire departments prepare grant applications, because he thinks this is forbidden by 44 CFR Part 13.

Is Mr. Harrington correct? A quick review of 44 CFR Part 13 reveals that it concerns uniform administrative requirements for grants to state and local governments. While the section contains lots of fascinating requirements, it is utterly silent on the ethics of who writes or pays for a grant proposal—which is not surprising, since I have never seen any Federal regs or RFPs that would preclude an applicant from getting help in grant writing, paid or volunteer.

While Mr. Harrington seems stuck on 44 CFR Part 13, I think he probably means Office of Management and Budget (OMB) Circular A-87, which covers cost principles for state, local and tribal governments and specifies how Federal lucre is to be spent. A key aspect of A-87 and grant administration in general is that, in addition to following Federal rules, public agencies must hew to their own procurement rules while squandering grant funds. As one who had several local government posts along the way, the most recent being the Community Development Director for the City of San Ramon in the early 1990s, and managed lots of federal and state grant funds, it basically comes down to the “smell test:” if you would not want your mother to read about how you spent Federal funds on the front page of the New York Times, don’t do it.

Federal regs don’t prevent a public agency from receiving grant writing help from others, including a potential vendor, but Mr. Harrington simply doesn’t like the idea and is intimidating AFG applicants by vague threats of dire consequences from scary sounding CFR citations. In other words, Mr. Harrington is probably a bureaucrat bully. Just like Clint Eastwood confronting Gene Hackman’s thugs in The Unforgiven’s saloon scene,** the only way to deal with bureaucratic bullies is to metaphorically blast away by reviewing the regs in question and, when one is satisfied that the threat is an illusion, sweetly asking the bureaucrat to cite chapter and verse to support his position. When he can’t follow through, you’ve got ’em.

Mr. Harrington is probably wrong, but his obstinate response illustrates an important point about dealing with agency contacts in general: although they can give you guidance, what’s written in RFPs ultimately counts. If something a program officer says contradicts the language of an RFP, assume the RFP is right. This can also work against you: if a program officer says that you don’t need a particular form, or that going over the page limit is acceptable, or that you don’t need to follow formatting requirements—all of which might make your life easier—don’t listen. Follow what you can read. Sometimes you’ll find internal contradictions in an RFP, and if so, contact the program officer and cite the conflicts, complete with page numbers and why you think a conflict exists. This may result in a modification to the RFP. But don’t assume that the verbal assurance of someone in the program will count for any more than the paper they’re written on.

Now that I’m satisfied that Mr. Harrington is pursuing his own agenda, rather than providing clear direction based on the regs, let’s examine the underlying ethical issue in juggling these rules and principles. While we do not go out of our way to be hired by vendors to prepare grant proposals for third party applicants, this does happen from time to time. For example, this almost happened with the current Carol M. White Physical Education Program (CMW PEP) RFP, which I blogged about in Brush the Dirt Off Your Shoulders: What to Do While Waiting for the Stimulus Bill to Pass. A large fitness equipment vendor called for a fee quote to have us write CMW PEP proposals for several of their school district clients. I explained that we would be happy to write the proposals as long as the vendor understood we would be working for the school districts, not colluding in getting their products purchased. I pointed out that their products would not be highlighted by brand name in the proposals, and the school districts would still have to follow applicable Federal regs, OMB circulars and their own purchasing rules.

If a vendor wants to try to rig bids, that’s there prerogative and they’ll ultimately be punished. As grant writers, our job is just to write ’em without resorting to unethical acts or breaking laws. To quote Bob Dylan quoting Hurricane Carter regarding how Carter felt about being a boxer, “It’s my work, he’d say, and I do it for pay.” A program officer like Mr. Harrington should no more care about who writes a proposal any more than he should care who fixes the applicant’s plumbing when it backs up. The punch line, of course, is that the vendor didn’t hire us for the CMW PEP, although we have written a few funded proposals under similar arrangements over the years, including one of my favorite Federal programs that is soon to get a huge influx of new money courtesy of the Stimulus Bill: Community Oriented Policing Services (COPS). If an applicant for any grant, however, is concerned about legal and ethical questions, they should ask for an opinion of law from their lawyer, not depend on random off-the-cuff interpretations by program officers.

Mr Harrington’s prejudice against grant writers has a long pedigree. Over the years, I’ve often come across the misguided conception that using an outside grant writer is somehow “cheating.” Way back in 1993 or so, when we were first in business, I tangled with a HUD Deputy Under Assistant Secretary about the then-new YouthBuild program regulations. When he discovered that we were grant writers working for a South Central LA nonprofit, he went ballistic and and accused me of “only wanting to line my pockets.” I responded by asking him if he was a volunteer and if he would like me to request his salary level and travel reimbursements through a Freedom of Information Act (FOIA) request. This calmed him, I got the interpretation of the regs I needed, and the proposal was ultimately funded. In discussing this post with my partner and wife, Kathy Seliger (a lucky woman, she gets to hear my pontifications 24 hours a day), and she pointed that hiring a grant writer is no more cheating than a woman wearing makeup to look her best. If you want to put the best face on your next grant proposal, call a qualified grant writer to apply proposalese makeup to make your application sparkle. While we do sometimes turn down assignments, it is not for the reason imagined by Mr. Harrington, but rather for real ethical problems determined by applying the simple smell test described above. You can also apply the smell test to bureaucrats, and if what they pitch seems wrong, it often is.


* The bureaucrats I am needling in this post are Federal program officers, who are also featured in my last post, Stimulus Bill Passes: Time for Fast and Furious Grant Writing. Not to worry: no Program Officers were actually harmed in the writing of this post.

** The Unforgiven is by far the best modern Western. As Clint’s Bill Munny responds to an accusation of being a “cowardly son of a bitch” for shooting an unarmed bartender in the saloon scene, “Well, he should have armed himself if he’s going to decorate his saloon with my friend” (the dead Morgan Freeman). Words to live by in challenging bureaucrats, who often only arm themselves with self-importance and don’t take the time to understand their own regs.

FEMA and Grants.gov Together at Last

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

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

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

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

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

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

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

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

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

FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program

Last year I railed about the Federal Emergency Management Agency’s inability to post the Assistance to Firefighters Grants program RFP on Grants.gov in a timely fashion in “FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats.” In addition, I sent a nastygram to FEMA about this failure, which someone named “R. David Paulison” responded to seven months later, as noted in the third bullet of January Links. That it took seven months to respond to a letter complaining about timeliness might be indicative of further problems.

You might imagine that FEMA would’ve solved the problem this year—in which case you’d be wrong. The Assistance to Firefighters Grant (AFG) Program 2008 Fire Prevention and Safety Grants (warning: link goes to a .pdf) program RFP was issued on Jan. 29, but it’s still not on Grants.gov as of this writing. Furthermore, the RFP doesn’t even include a Catalog of Federal Domestic Assistance (CFDA) number attached—which it should, since, according to the CFDA website, “As you know, the CFDA provides a full listing of all Federal programs available […]” and all federal programs are supposed to have a CFDA number in the body of their RFPs.

(As an aside: the CFDA website isn’t working at the moment because “We are upgrading our site to provide increased transparency, greater access to assistance information and to better support the American Recovery and Reinvestment Plan.” Isaac tried to visit it earlier this week and found it dead. This is somewhat strange because every other website, including ours, would leave the old version up until the new one is ready to go; only the government would take down the old website and leave nothing in its place. I’ve never seen Amazon.com intentionally prevent me from buying books because they wanted to improve the interface. Keep this in mind when contemplating the various proposals that have been floating around regarding government-mandated electronic medical records.)

Nonetheless, a print version of the CFDA lists the AFG’s CFDA number as 97.044. I took that to Grants.gov’s search page and tried the CFDA number and variations on AFG. No dice. In other words, the CFDA and Grants.gov websites must not talk to one another, since AFG appears in the CFDA but not in Grants.gov. More importantly, FEMA still hasn’t posted the AFG RFP to Grants.gov. Maybe FEMA will three days before the deadline, as they did last year. I’m really glad Tucson isn’t susceptible to hurricanes.

But there is some good in this mess, which you can find on page 10 of the RFP: “Applicants are allowed to hire, or otherwise employ the services of, a grant writer to assist in the application process.” Great news! Great, but unnecessary—funders can’t prohibit or forbid grant writers; how you prepare your application is your own affair. Typically, you just can’t charge expenses to a contract before you have a contract to charge them to, and you can’t hire grant writers on a contingent-fee basis. But no ethical grant writer will work on a contingent-fee basis, as we explain in our FAQ.

FEMA Tardiness, Grants.gov, and Dealing with Recalcitrant Bureaucrats

The Federal Emergency Management Agency (FEMA)—the same guys who brought us the stellar job after Hurricane Katrina—issued the Assistance to Firefighters Grants program on what Grants.gov says is March 26, 2008. But the deadline was April 04, 2008, which is absurdly short by any standards, let alone those of a federal agency. I sent an e-mail to the contact person, Tom Harrington, asking if there was a typo. He responded: “No mistake. The Grants.gov posting was a little delayed. The application period for AFG actually started on March 3rd.” So, unless you have psychic powers, it is unlikely that you would have known about this opportunity. This “little delay” is for a program with $500,000,000 of funding. If anything has changed at FEMA since Katrina, it’s not obvious from my encounter with the organization; as President Bush said to FEMA’s chief after Katrina, “Brownie, you’re doing a heck of a job!

I was curious about how and why this deadline foul-up occurred, leading to an e-mail exchange Tom, who appears to be a master at not knowing about the programs he is a contact person for. It’s instructive to contrast my experience with him and the one with the state officials who I wrote about in Finding and Using Phantom Data. Bureaucrats come in a variety of forms, some helpful, like the ones who provided dental data to the best of their ability, and some not, such as Tom.

I replied to his e-mail and said, “Do you know who was responsible for the delay, or can you find that out? Three weeks is more than a ‘little’ delayed.” He gave me a wonderfully bureaucratic response: “I don’t know if there is anyone specific to blame; the process is to blame.” That’s rather curious, since processes don’t put grant opportunities on Grants.gov—people do, assuming that federal bureaucrats should be considered people. And even if the “process” is to blame, someone specific should to change the process so problems like this one don’t recur. I replied: “If ‘the process is to blame,’ what will you do differently next year to make sure this doesn’t happen again?”

His response contradicted his earlier statement: “Assure that those responsible for the paperwork are informed that they are responsible for the paperwork.” In other words, someone is responsible for this year’s problem—but who is that person? I inquired: “I’m wondering who is responsible for the paperwork or who will be responsible for it.” And Tom responded: “As soon as the policy is written, we’ll know. At this time, there is no policy.” Notice how he didn’t answer my first question: who is responsible? Instead, he used two clever constructions, by saying that “we’ll know,” rather than him or some specific person with FEMA. Instead, some nebulous “we,” with no particular individual attached to the group will know. The passive construction “there is no policy,” avoid specifying a responsible person. Tom uses language to cloak the identity of whoever might be in charge of the FEMA policy regarding Grants.gov. The e-mail exchange went for another fruitless round before I gave up.*

If you were actually interested in finding the truth about who caused the delay, or how it will be avoided next year, you’d have to try and find out who is really in charge of the program, contact that person, and probably continue up the food chain when that person gives you answers similar to Tom’s. Normal people, however, are unlikely to ever try this, which is why Tom’s blame of “the process” is so ingenious: he avoids giving any potential target. Someone caused this problem, and to find out who would probably take an enterprising journalist or an academic highly interested in the issue.**

Sadly, I’m not going to be that person, as I write this chiefly to show a) how bureaucracies work, which isn’t always in the positive way I described in “Finding and Using Phantom Data”, and b) why you should be cognizant of the potential drawbacks of Grants.gov. Regarding the former, if you need to find information from reluctant bureaucrats, you have to be prepared to keep trying to pin them down or become enough of a pest that they or their bosses would rather get rid of you by complying with your request than by stonewalling. If the bureaucrats at the health department from “Finding and Using Phantom Data” had been as unhelpful as Tom, I would’ve begun this process because data is more important than the deadline for this program.

This strange interlude in the Never Never Land of FEMA also tells us something important about Grants.gov: the primary website for notifying interested parties about government grants is as useful as the organizations who use it. Any fire department that depends on Grants.gov for announcements just got screwed. Despite the designation of Grants.gov as “a central storehouse for information on over 1,000 grant programs[…]”, it’s only as good as the independent organizations using it. Perhaps not surprisingly, given FEMA’s past performance, that organization doesn’t appear interested in timeliness. Incidents like this explain Isaac’s wariness and skepticism toward Grants.gov, and why it, like so many government efforts, tends not to live up to its purpose. And when something goes wrong, whether it be FEMA during Hurricane Katrina or propagating information about grant programs, don’t be surprised if “the process is to blame.”

EDIT: You can see our follow-ups to this post in “FEMA Fails to Learn New Tricks With the Assistance to Firefighters Grant Program” and “FEMA and Grants.gov Together at Last.”


* Tolstoy wrote in the appendix to War and Peace (trans. Richard Pevear and Larissa Volokhonsky):

In studying an epoch so tragic, so rich in the enormity of its events, and so near to us, of which such a variety of traditions still live, I arrived at the obviousness of the fact that the causes of the historical events that take place are inaccessible to our intelligence. To say […] that the causes of the events of the year twelve are the conquering spirit of Napoleon and the patriotic firmness of the emperor Alexander Pavlovich, is as meaningless to say that the causes of the fall of the Roman Empire are that such-and-such barbarian led his people to the west […] or that an immense mountain that was being leveled came down because the last workman drove his spade into it.

You could say the same of trying to study the manifold tentacles and networks of the federal government, which is only moved, and then only to a limited extent, during a truly monumental and astonishing screw-up like Katrina, which is itself only a manifestation of problems that extend far backwards in time and relate to culture, incentives, and structure, but such failures are only noticed by the body politic at large during disasters.

** Even journalists get tired of fighting the gelatinous blob. As Clive Crook writes in The Atlantic, “Personally, and I speak admittedly as a resident of the District of Columbia, I find the encompassing multi-jurisdictional tyranny of inspectors, officers, auditors, and issuers of licenses—petty bureaucracy in all its teeming proliferation—more oppressive in the United States than in Britain, something I never expected to say.”