Tag Archives: HUD

HUD’s Lead Hazard Reduction grant program and the hazards of government autopilot

The NOFA for HUD’s Lead Hazard Reduction (LHR) grant program just came out, and it has $275 million to undertake, as usual, “comprehensive programs to identify and control lead-based paint hazards in eligible privately-owned target housing.” LHR NOFAs are issued every year or two, which is fine, but those of you who are alive and able to read or access the Internet are probably aware that there’s another health hazard out there this year, and it’s a health hazard that’s probably more urgent than lead-based paint—lead-based paint has been illegal in the US since 1980 and HUD’s been funding LHR grants for at least 30 years (we know, because we’ve written so many funded LHR proposals). It’s hard to believe that there’re all that many housing units left in the US with lead-based paint, but HUD soldiers on.

Sure, lead is a health hazard, but COVID-19 is also a health hazard; if I had to bet which one most persons would consider more hazardous right now, I’d bet on COVID-19. $275 million may be a small amount of money by federal standards, but I wonder how much the staff at HUD thought about whether public housing authorities (PHAs) and cities want to work on lead abatement this year, versus how much they’d like and need to work on COVID-19 abatement; $275 million can buy a lot of masks, education, and tests (although tests are still in short supply right now). It’s not really the fault of HUD bureaucrats, since LHR grants have been authorized by Congress for for decades and Congress usually just keeps funding programs like this, no matter what’s going on in the real world. Nonetheless, it would seem to me that a simple, bipartisan vote to amend the underlying legislation would be relatively easy—instead, LHR, at this point, is indicative of the dangers of government autopilot. Autopilot is fine in clear, consistent weather, but it can be disastrous during unpredictable storms—and the world has been hit by a storm in 2020.

I’m not presenting an argument against lead-hazard control: I don’t know enough to say whether lead-hazard control remains, in the absence of a pandemic, a (relatively) good idea or a (relatively—compared to other health-related activities) bad idea. I’ll posit, however, that a lot more people are going to die and suffer from COVID-19 this year, than will die or suffer from lead-based paint, and the failure to change course in the face of new events is evidence of deeper malaise.

HUD Gets Back in the Job Training Biz: “Jobs Plus Pilot Program” NOFA Released

HUD just issued a NOFA (Notice of Funding Availability, which is HUD-speak for RFP) for the Jobs Plus Pilot Program. There’s $24 million up for grabs, with grants to $3 million, for Public Housing Authorities/Indian Housing Authorities (PHAs/IHAs). While the issuance of a new HUD NOFA is not usually all that interesting, this one is because it represents a shift in HUD’s priorities.

As I wrote last February, job training is one of the current favored project concepts in grant making. There are at least 47 federal job training programs, or possibly 48 including the newly minted Jobs Plus. You may not remember, though I do, that President Obama made a big fuss about job training in his most recent State of the Union address and vowed to unleash Vice President Biden to study federal job training initiatives in hopes of simplifying things.


That was the last I heard of this noble quest, and, as far as I can tell, the herd of federal job training programs continue to thunder across the plain. It’s job training business as usual, with the random new program tossed in for good measure.

This is not, however, what made me notice this notice.

At one time HUD had several competitive job training programs, including our old friend YouthBuild, which HUD managed for about 12 years. Suddenly, in the waning days of the reign of George Bush the Younger, Congress got the bright idea that maybe it isn’t such a good approach to have HUD, which is supposed to be involved in housing, fund job training programs. Not a bad reform, since HUD’s job training grant programs were not coordinated with other federal job training programs, particularly the ones operated by the Department of Labor. YouthBuild and other HUD job training programs were eventually transferred to DOL in a previous effort to “simplify things.” Now that eight years or so of DOL running former HUD job training programs have passed, it seems perfectly appropriate to make things more complex again by having HUD manage yet another job training program.

A cursory look at the Jobs Plus Pilot reveals that there’s not much new here, since it’s more or less a rehash of the “workfare” job training concept that emerged from the 1996 compromise Welfare Reform legislation negotiated by President Clinton and Speaker Gingrich. The basic idea was (and is) to tie public income supports, like TANF, to job training. This naturally works better when the economy is producing lots of entry-level jobs.

In the case of Jobs Plus, the target population is residents of the 250 or so remaining large public housing projects* that survived the lunacy of the now almost forgotten HOPE VI program that funded the demolition of thousands of public housing units across America. Even though we wrote some HOPE VI proposals, it always struck me as incredibly stupid to tear down the housing of last resort for the poorest Americans. The good news now is that, if your public housing development still stands, HUD is willing to toss you a job training bone. Of course, there’s nothing to prevent public housing residents from accessing the myriad of job training programs surrounding them. As a grant writer, however, I agree and have to ask, “why have 47 job training programs when 48 will do?”

* When writing a grant proposal about public housing, never use the term “housing project.” Instead, these are always referred to by the more PC “housing development.” Of course, I’m a geezer who grew up in the very poor North Minneapolis neighborhood adjacent to the huge Sumner Field Homes and associated public housing high rises.

I used to play at the Sumner Field park and kid and adults referred to this area as “the projects.” I’ve been to re-education camp since then and banished “projects” from my proposals. By the way, if you follow this link you’ll learn that a huge HOPE VI grant was used to destroy the entire Sumner Field Homes and associated buildings in 1998, displacing 97% of the over 3,300 poor residents in the name of the “new urbanism.” Not to worry: a much smaller mixed-use development replaced it, but there is no word on what happened to the thousands of residents who were tossed out.

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.


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.

RFPs for “National Nonprofits,” like the Rural Capacity Building for Community Development and Affordable Housing Grants, are Effectively Wired

It’s barely worth writing this post, but we hope to save someone from the danger of applying for a program that for which they’re probably not a competitive applicant—even if they’re nominally eligible.

Subscribers to our e-mail grant newsletter recently saw an RFP for the “Rural Capacity Building for Community Development and Affordable Housing Grants” program. Only “national nonprofits” are eligible. The eligibility requirement is doubly strange, because the purpose of the program is to “to enhance the capacity and ability of local governments, Indian tribes, housing development organizations, rural CDCs, and CHDOs, to carry out community development and affordable housing activities” (emphasis added).

So a national nonprofit is supposed to be helping local efforts. Those of you who find this somewhat perplexing are not alone. It’s almost certain that this application has already been de facto wired for an organization or set of organizations. There just aren’t many nonprofits with real presences in five or more states. If you don’t already know that you’re going to get this, you’re probably not going to get it.

Programs like “Rural Capacity Building for Community Development and Affordable Housing Grants” are effectively earmarks without an earmark.

There’s another lesson embedded in the Rural Capacity Building for Community Development and Affordable Housing Grants RFP: always read the eligibility requirements very, very carefully. It would be easy to read the project description, get excited at the possibilities, and overlook the unusual eligibility requirements.

Occasionally, by the way, we do get hired to write wired grant applications. This might seem counterintuitive: why hire consultants to write a complete and technically correct grant proposal when you already know that you’re going to get the award? The reason is simple: the funding agency still needs a plausible, and ideally good, proposal to present to anyone curious about why Joe’s Nonprofit got a grant and Jane’s Nonprofit didn’t. The funder doesn’t want to embarrass itself, and Joe’s Nonprofit needs cover. Even wired grants sometimes need a grant writer.

December Links: HUD, Emergency Solutions Grants, Boating Safety Grants, What’s Wrong with Liking Quiet Time, Real Dangers, Parents in Prison, Happy Porn Stars and More

* In a very important announcement, HUD has decided to

revise the regulations for the Emergency Shelter Grants program by establishing the regulations for the Emergency Solutions Grants program, which replaces the Emergency Shelter Grants program. The change in the program’s name, from Emergency Shelter Grants to Emergency Solutions Grants, reflects the change in the program’s focus from addressing the needs of homeless people in emergency or transitional shelters to assisting people to quickly regain stability in permanent housing after experiencing a housing crisis and/or homelessness.

Some observations:

1. The name change doesn’t matter.

2. This is only going to confuse people further.

3. This isn’t going to help people who actually need services, but:

4. It will certainly create more work for HUD bureaucrats.

* The Water Boating Safety Grants are out, and they’re now being provided under the Department of Homeland Security (DHS). Aren’t they supposed to be catching terrorists, not checking for life vests on dinghies?

* “The Quiet Ones.” This describes me, and wanting quiet sometimes makes me feel increasingly out of place, or out of time. The Hacker News discussion is also good, and Paul Graham said this:

I think the fundamental problem with noisy people is not that they’re inconsiderate, but that they don’t have any train of thought to interrupt, and they thus don’t realize the havoc they’re wreaking.

When I was living in Providence, working on On Lisp, I told my loud but well-meaning neighbors that I was writing a hard computer book, and that made them be quiet. Ordinary people can understand that you need quiet if you’re working on some specific, hard task, like doing math homework. What they don’t grasp is that someone would want their mind to work that way all the time, as a matter of course.

* “The attention paid to terrorism in the U.S. is considerably out of proportion to the relative threat it presents. That’s especially true when it comes to Islamic-extremist terror. Of the 150,000 murders in the U.S. between 9/11 and the end of 2010, Islamic extremism accounted for fewer than three dozen.” My favorite question when I hear people discussing the contemporary impact of terrorism is this: About how many Americans die in car accidents every year? If they don’t know the answer, they probably aren’t all that serious about evaluating real dangers and priorities.

* Coping with parents in prison.

* “Efforts to Curb Social Spending Face Resistance.”

* “The Real Estate Deal That Could Change the Future of Everything:” letting local people invest small amounts in local projects. The barriers are primarily regulatory.

* “Study: Porn stars aren’t ‘damaged:’ A report finds adult actresses are happier than the rest of us — and that being naked might lead to self-esteem.” This leads to the obvious question: Why do these stereotypes persist?

* Immigrants lead plunge in U.S. birth rate. This is actually a bigger problem than many people realize.

* “Cirque du Soleil’s extravagant ‘Iris’ will close Jan. 19.” We wrote a funded $4 million HUD UDAG about ten years ago for the parking for the theater component of this mixed use project in Hollywood for the now-defunct Los Angeles Community Redevelopment Agency. It wasn’t a very well designed project then and still isn’t.

* Guy Kawasaki’s APE: Author, Publisher, Entrepreneur–How to Publish a Book describes what I’m going to be doing and what you might be thinking about doing.

* Awesome: Soaring Rents Drive a Boom in Apartments.

* “Michigan Goes Right-to-Work.” As Yglesias says, “It’s only going to have a modest impact in the short-term, but far and away the biggest economic news of the week from a long-term perspective has got to be Michigan’s rather sudden transformation into a right-to-work state.”

* If Peter Thiel And Garry Kasparov Are Right, Then We’re In Trouble. I pre-ordered their book, The Blueprint.

* Related to the above link: “Teach U.S. kids to write code.” I would add, however, that we should teach it better than we teach, say, English, math and physics.

* My favorite recent weird RFP is the Black Duck Joint Venture Competitive Grant Program (BDJV). There are grants up to $120,000 and up to four available awards.

Why HUD Hasn’t Released the Total Funding Amount for the Lead-Based Paint Hazard Control (LBPHC) and Demonstration Program NOFAs?

HUD just announced the Lead-Based Paint Hazard Control (LBPHC) Program and its sister program, Lead Hazard Reduction Demonstration Grant (LHRD) Program NOFA. The NOFA, however, doesn’t list how much money is available or the maximum grant amounts for either program—instead, it has highlighted “XX” and “XXX” variables:

I sent a note to Michelle Miller, the Director of HUD’s Programs Division, noting the absence of the funding amount and maximum grant amount, under the assumption that it was a mistake. She promptly (always a pleasant surprise) wrote back:

Actually it is correct Jake. Since federal budgets have not been appropriated we do not know the total dollars available. That will be announced as soon as we know. However, does affect anyone putting in an application since the award amounts are listed

And now we’re sharing her answers with those of you who are wondering the same thing I was. As of this writing,* Congress hasn’t passed a FY ’13 budget or yet another Continuing Resolution, so HUD is stuck in budgetary limbo. But HUD assumes, probably correctly, that Congress will eventually authorize LBPHC and LHRD money.

Smart organizations are going to start their applications now, since the NOFA has been published.

In past years, the two programs have had more than $100 million available, which makes them an excellent source of funding for cities and community development agencies; we’ve written seven funded LBPHC grants over the years and so are very familiar with the program. For a primer, see Isaac’s post, “HUD’s Lead-Based Paint Hazard Control Program (LBPHC) Program Explained.”

Despite the frustration of not knowing exactly how much money will be allocated to these programs, we have to give HUD credit for two things: first, it’s breaking the increasingly common pattern of offering only thirty-day deadlines; very short deadlines make it much harder for nonprofits to prepare their best application. Second, Michelle replied to my e-mail. I know we’ve written many posts that castigate bureaucrats for various misdemeanors and kinds of incompetence, but we do want to praise responsive bureaucrats who do come through.

* Free proposal phrase.

HUD’s Confusing Continuum of Care (CoC) Program Explained

HUD just released the FY ’13 Continuum of Care (CoC) Program NOFA, with $1.6 billion available for an array of housing and related services for the homeless. But the process of trying to access that money is deliberately confusing. We’re going to explain how it works in this post, mostly for our own amusement but also in an attempt to educate readers.

“CoC” is the acronym for the federal Continuum of Care program. But “CoC” is also the acronym used for local Continuum of Care programs, as well as local or regional Continuum of Care bodies. To access federal CoC grant funds to help implement the local CoC program, potential applicants—like garden-variety nonprofits—have to go through the local CoC body, which is usually a joint powers authority set up to access federal CoC dollars by local governments, or, in some cases, the state itself. That’s a lot of CoCs, any way you look at it.

Since there is no shortage of acronyms, it would have been nice if the GS-15s at HUD had done a little CoC differentiation to reduce the confusion. Regardless of the nomenclature confusion, most nonprofit or public agencies (which are eligible CoC grantees) cannot apply directly to HUD. Rather, the CoC application has to be first submitted to the local CoC and approved for inclusion in the master CoC application sent in by the CoC.*

Astute readers who know anything about bureaucratic processes are now thinking that the CoC local body system created by HUD sounds like a recipe for confusion and potential collusion, at best.

Those readers are correct. The CoC system has become, in effect, a cartel, with each local CoC able to encourage local providers it likes and discourage ones it doesn’t like, or discourage ones that are not part of the current service delivery system. HUD has in effect created a class of self-perpetuating apparatchiks. This is the flip-side of mandating collaboration: your putative collaborators can easily take you out at the kneecaps, and it’s an example of the problems we’ve written about in “What Exactly Is the Point of Collaboration in Grant Proposals?” and “Following up on Collaboration in Proposals and How to Respond to RFPs Demanding It.”

The fundamental problem here is that the local CoC can stifle subsidiary organizations, and that stifling is mandated by the CoC NOFA itself:

24 CFR 578.9 requires CoCs to design, operate, and follow a collaborative process for the development of an application in response to a NOFA issued by HUD. As part of this collaborative process, CoCs should implement internal competition deadlines to ensure transparency and fairness at the local level.

If you, a potential applicant, didn’t hear about the “internal competition deadline,” you can’t apply. And those deadlines aren’t published in any regularized way or forum, like, say, the Federal Register. Because you have to do the local submission to be part of the CoC’s HUD submission, it makes it more complicated for a garden variety nonprofit to get a CoC grant. Though we’d definitely be interested in working for some malcontent organization that wants to submit a local proposal at the risk of rejection, then appeal to HUD with a claim that the local organization is failing to perform its duties, no one has called us with this proposition yet, though the situation is probably common in the CoC / homeless services world. These are the kinds of stories that, if we had any real reporters left in America, would be covered in the media.

We have some history with CoC, which was originally part of the Reagan era McKinney-Vento Homeless Assistance Act.” Congress passed it in 1987. The original CoC program consisted of three separate grant programs: the Supportive Housing Program, the Shelter Plus Care Program, and the Single Room Occupancy Program. When Seliger + Associates was getting started, one of the first funded proposals we wrote was a $3,000,000 Supportive Housing grant for a nonprofit in Northern California. This was a direct HUD submission, as it was before the local CoC body infrastructure was created.

For reasons that are not clear to us, during the tenure of Andrew Cuomo, or Frankenstein as we used to refer to him around the office because of his uncanny resemblance to our bolt-necked friend, these programs were pumped up as part of Clinton-era response to the “homeless problem” of that time and the CoC system was birthed. As a result, a new layer of bureaucracy began to be consolidated, running parallel to the city, county or state level (in this respect, CoCs are a bit like Community Action Agencies).

We’ve interacted with this new layer of bureaucracy. Although we have written CoC applications in many states, we are most familiar with Los Angeles’s CoC—the Los Angeles Homeless Services Authority (LAHSA). This bureaucratic gem sprung forth fully grown from LA City and County at the behest of HUD about 15 years ago like Athena from the head of Zeus. It now has a $73,000,000 budget and over 100 steely-eyed bureaucrats, but LAHSA is virtually unknown outside of the homeless services provider community.

When HUD changed the rules, there had to be a Continuum of Care Plan for a local area in order for an applicant to be eligible (LAHSA is in charge of the plan in most of L.A. County). And the applicant had to fit into the Plan. Isaac actually wrote a nominal statewide Continuum of Care Plan for Arkansas around 1997 for a housing authority applicant, because Arkansas didn’t want to do one, but our client couldn’t apply without one. So, we just wrote a CoC Plan to enable our client to apply.

Eventually, the local-level CoCs got consolidated in the late 1990s. Unfortunately, if you weren’t part of the Continuum of Care syndicate in the mid-90s, you might still not be. But almost no one understands this, and the only people who do are the people working for the local CoCs. In the case of LAHSA, only three of of the 88 municipalities in Los Angeles County—Long Beach, Glendale, and Pasadena—have opted out of LHASA and have their own CoC bodies. In Pasadena, it’s the Pasadena Housing and Homeless Network. We assume an interest in the administrative overhead that is gleaned from being designated as a CoC has something to do with the three LAHSA outliers in the LA County CoC ecosystem.

By now, CoC operates somewhat like passthrough funds, except that it isn’t part of the two other federal Block Grant systems: Community Development Block Grant (CDBG) from HUD and the Community Services Block Grant (CSBG) from the Office of Community Services (OCS).

This raises the obvious question: Why isn’t the CoC grant program part of either CDBG or CSBG? For example, every jurisdiction that receives a CDBG Block Grant must prepare a Consolidated Plan every five years, with annual Action Plan updates. If you browse through any Consolidated Plan, you’ll notice an emphasis on homelessness and homeless programs. But, instead of using the existing system, a parallel system has been legislated into existence, with the usual set of costs and confusions. This post is designed to dispel some of the confusions. But we don’t have the power to dispel the costs.

* I wrote this sentence to see how many times I could work “CoC” into it.

HUD Issues the FY ’12 Indian Community Development Block Grant (ICDBG) NOFA Not Long After the FY ’11 NOFA

HUD just issued the FY ’12 Indian Community Development Block Grant (ICDBG) NOFA (Notice of Funding Availability, which is HUD-speak for RFP). There’s about $61 million available for federally recognized Tribes, Alaskan Native Villages and selected Native American organizations. This is a great opportunity for eligible Native American applicants to fund housing, economic development and community facility projects, and maximum grants range from $600,000 to $5,500,000, depending on the location and number of persons impacted. The question is, why am I blogging about it, since it seems like another run-of-the-mill federal grant process?

The answer is in the timing of the NOFA release and deadline.

The timing issue caught my eye because the FY ’11 ICDBG deadline was June 15. The FY ’12 ICDBG NOFA was released on October 4 and the deadline is January 4, so two “annual” funding cycles will be completed within a year! Faithful readers will recall that I wrote several posts in halcyon days of the Stimulus Bill passing in early 2009, including February 2009’s Stimulus Bill Passes: Time for Fast and Furious Grant Writing. In it, I correctly predicted that the feds would have more than a little trouble shoveling $800 billion out of the door.

The Stimulus Bill also distorted the more or less predictable flow of other discretionary grant programs like ICDBG; while the Stimulus Bill unleashed a huge quantity of additional grant funds, there were few, if any, additional personnel to manage the process, as I observed then:

My experience with Federal employees is that they work slower, not faster, under pressure, and there is no incentive whatsoever for a GS-10 to burn the midnight oil. Federal staffers are just employees who likely don’t share the passion of the policy wonks in the West Wing or the grant applicants. They just do their jobs, and, since there are protected by Civil Service, they cannot be speeded up. Also, there are no bonuses in the Federal system for work above and beyond the call of duty.

The nearly back-to-back release of ICDBG NOFAs is likely the result of the Stimulus Bill backlog—something like the boa constrictor eating an elephant in Saint-Exupéry’s charming novella, The Little Prince. ICDBG-eligible applicants had to wait for the FY ’11 grants to be digested, and then they have the opportunity to apply all over again a few months later.

The lack of a federal budget for three years and the reliance on Continuing Resolutions (CRs) to fund federal agencies likely doesn’t help. While the media focuses on the upcoming election and never-ending economic challenges, Congress passes appropriation bills using CRs, which allows FY ’12 funds, like ICDBG, to become available. You can expect a flood of backlogged federal programs to issue RFPs in the next few months.

Given the chaos in the federal budgeting process, it seems like a good bet to apply for any grant programs that come along now because the funding cycles for ICDBG and lots of other programs are pretty screwed up. In the case of ICDBG, I have no idea when the FY ’13 ICDBG NOFA will appear, but there’s an opportunity for a second bite of the apple this year. It seems to me that any ICDBG-eligible entity should bite that apple (or is it a salmon? I leave it to readers to decide).

A Lesson in Passthrough Funds and Capacity Building: ACF’s Non-Profit Capacity Building Program NOFA

If you read this week’s grant newsletter, you probably saw the NOFA for the Administration for Children and Families’s “Non-Profit Capacity Building Program,” which I first thought meant “pass-through funds,” since the purpose is “to increase the capacity of a small number of intermediary grantees to provide specific assistance to improve the sustainability of and expand services provided by small and midsize nonprofits in communities facing resource hardship challenges.” Do you know what would help those agencies? Money.

Unfortunately, I was wrong: it initially looks like pass-through funds but isn’t.

If you dig into the NOFA, you’ll find that “specific assistance” means that applicants should propose activities like “a comprehensive strategy of various learning activities and methods to increase the knowledge, skills, and abilities of recipients to implement performance management systems as well as any other best practice areas to target for improvement.” If I were a small nonprofit, I’d prefer that “specific assistance” mean “direct funding,” but here it doesn’t; the best you can do is use “a small portion of funds [. . .] to provide minor capital investments in the capacity of certain recipients such as the purchase of specific software or systems to improve infrastructure.”

I’m guessing that, if you surveyed the nonprofits “facing resource hardship challenges” to be “helped” by well-meaning but paternalistic intermediary organizations if they’d prefer “various learning activities and methods” or “cold, hard cash,” they’d prefer the latter. Isaac has written extensively on the challenges and opportunities nonprofits face in the current climate, and a dearth of training hasn’t been one. As he said, when donations and contracts dry up, smart nonprofits turn to grants. Less smart ones disappear. I think the ACF’s nominal purpose in running this program is to help small nonprofits. Its real purpose, however, is to help the intermediate nonprofits that are supposed to run a variation on train-the-trainers.

How do you do that? The NOFA itself says that “applicants will focus their organizational development assistance program on developing and implementing performance management systems that enable organizations to measure their progress and improve their performance towards intended outcomes.” So it wants nonprofits to basically act like Accenture, IBM Global Services, or the other big consultants that are frequently the target of Dilbert. We’ve written a number of funded proposals over the years to do activities like this, and one key is understanding what I’ve laid out above: you’re passing out training, not money.

You don’t see a huge number of pass-through awards because they just increase administrative friction: ACF is paying staffers to write the RFP, review applications, and so forth, it isn’t going to give grants to “intermediary” nonprofits to… write a mini-RFP solicit applications, review applications, and so forth, probably to the tune of 10 – 30% of the grant. You’ll find pass-through grants at the state level, but very rarely lower than that.

Foundation appeal clients occasionally want to run variations on pass-through programs. Some clients, for example, will provide scholarships to people with a particular illness, like Groat’s disease. We tell them not to do this, however, because if the funder wants to fund any kind of cash payment scheme, they’ll do so directly and cut out the middleman. You want to look like something more than the middleman. Foundations mostly like direct services. As the “Non-Profit Capacity Building Program” shows, so do the feds.

Processes and Outcomes: The Shape of Another Grant Wave, featuring HUD’s Choice Neighborhoods Initiative

Social and human service proposals are usually geared toward outcomes: you’re going to get a grant to provide after school services to at-risk youth, which will reduce the number of them who drop out of high school or get unfortunate tattoos they’ll later regret by 25%. To apply, you’re going to write a proposal based loosely on the same format discussed in “Project NUTRIA: A Study in Project Concept Development,” except you’re going to give academic enrichment and life skills training to at-risk youth instead of having them hunt nutria.

But you’ll sometimes face RFPs that don’t want you to provide direct services: they want you to improve your organization’s process, evaluate community needs, or otherwise do something to that effect. You’ll get RFPs that ask you to primarily engage in process: developing curricula, engaging in social change, running planning charettes, and so forth. Process grants are designed to further the organization’s capability—they might be for training staff, for coordinating development, or community engagement.

We’ve seen more of those RFPs lately. For example, the Promise Neighborhoods Program doesn’t require you to provide services—it requires you to evaluate your neighborhood and see what kinds of services it might need. The RFP is almost all needs section and very little project description.

This is also true of its more recent cousins. You can expect RFPs that emphasize things like “planning” to be mostly process oriented. This week’s Grant Alert e-newsletter, for example, contains the Choice Neighborhoods Initiative–Planning Grants, which certainly means “planning” as opposed to “implementation.”

In process grants, you should remember that activities, outcomes, and objectives are often all the same: you’re planning what to do later, not what’s going to happen now. Your “outcome” is whether you planned successfully. Part of your job, as a grant writer, is to realize which you’re doing. Outcome-oriented programs are far more common than process-oriented ones, but if you’re applying for a process-oriented program, don’t write it like you’re focused on outcomes. Sure, you might want to mention ultimate outcomes, but you primarily want to discuss the journey to get there.

EDIT: For another example, consider the USDA’s 2010 program, Hunger-Free Communities Grants:

There are two models of grants: planning and assessment grants and implementation grants. A community may only apply for one model of grant as part of this grant solicitation; however, those communities receiving a planning and assessment grant may apply for an implementation grant in a future year if additional funds are made available to continue this program.

The difference between this USDA RFP and many others is that this one makes explicit what many others assume the grant writer knows.