Tag Archives: HCI

More RFP Looney Tunes, This Time from the Centers for Medicare & Medicaid Services Health Care Innovation Award Program

Having been a grant writer since before the flood, I should not be flummoxed by a hopelessly inept RFP. I wasn’t flummoxed by the recently completed Centers for Medicare & Medicaid Services (CMS) Health Care Innovation (HCI) Awards Round Two process, but I was impressed by the sheer madness of it.

This Funding Opportunity Announcement (FOA, which is CMS-speak for “RFP”) was exceptionally obtuse and convoluted. I should expect this from an agency that uses 140,000 treatment reimbursement codes, apparently including nine codes for injuries caused by turkeys.

The HCI FOA was 41 single-spaced pages, which is fairly svelte by federal standards—but, in addition to the usual requirements for an abstract, project narrative, budget and budget narrative, it also includes links to templates for a Financial Plan, Operational Plan, Actuarial Certification and—my personal favorite—the Executive Overview. The Financial Plan was a fiendishly complex Excel workbook, while the Operational Plan and Executive Overview were locked Word files.

Since the Word documents were locked, spell check and find/replace didn’t work in the text input boxes. Every change had to be made manually. Charmingly, the Operational Plan template had no place to insert the applicant’s name or contact info. So when the file is printed for review, which I’m sure it will be, and gets dropped on the floor with several other proposals, which is possible, there’ll be no way to tell which Operational Plan is which.

This could be a problem in an Operational Plan.

My vote for the most fabulously miss-titled form is the “Executive Overview.” Remember: a one-page abstract was also required, so an Executive Overview seemed redundant until I realized it was 13 single-spaced pages, with tons of inscrutable drop-down menus and fixed-length text input boxes. It seems that CMS is confused as to the meaning of “overview.”

The Executive Overview was really another project narrative, disguised as a form. If one double-spaced the Executive Overview, it would be about 26 pages long. Although the FOA nominally allowed a 50-page project narrative, the length of the project narrative was effectively much shorter because of convoluted instructions that required the project narrative file to include other documents. Our project narrative ended up at 35 double-spaced pages—not all that much longer than the so-called Executive Overview.

This FOA also included four “innovation categories” that were obtuse and mostly interchangeable. The FOA required that the selected innovation category be listed four times, once in the abstract, twice in the project narrative and again in the Overview. Since the categories were confusing at best, our client changed their selection a couple of times during the drafting process, which meant it had to be changed in four different places each time.

The grant request amount had the same problem, except that it is also included in the Financial Plan, budget narrative, cover letter and Actuarial Certification, as well as the abstract, project narrative, and Overview. So when the budget changed—which it inevitably did—each change had to occur in seven places to maintain internal consistency.

CMS, of course, never thought to link the various templates so that global changes could be made. But then again, why would they? After all, the authors of this FOA don’t write proposals and aren’t concerned with simplifying the process, which brings me back to the nine categories of turkey injury treatment. I wonder who keeps stats on turkey injuries. I would like to meet the GS-13 in charge of domestic fowl attacks at the Department of Agriculture.