Tag Archives: IHEs

Parsing the Department of Education’s “Developing Hispanic-Serving Institutions” (HSI) Program RFP–Which Colleges are Eligible?

As we’ve written before, parsing an RFP sometimes seems like deciphering the Talmud. The just-issued ED Developing Hispanic-Serving Institutions (HSI) RFP is a case in point.

HSI is a venerable program that provides grants to Institutions of Higher Education (ED-speak for “two- and four-year colleges and universities”) deemed to be “Hispanic-Serving Institutions.” But what is an HSI? To paraphrase President Clinton, it depends on what the meaning of “HSI” is? The RFP states:

In addition to basic eligibility requirements, an institution must have at least 25 percent enrollment of undergraduate full-time equivalent (FTE) Hispanic students at the end of the award year immediately preceding the date of application.

(Emphasis added.)

Now we have to determine what “award year” means. On page 19 of the 87-page RFP, we finally learn that award year “refers to the end of the fiscal year prior to the application due date.” Which raises the question, why doesn’t the RFP just consistently replace “award year,” which no one understands, with “end of the last federal year,” which anyone involved in federal grants knows is September 30?

This conundrum came up on Friday when I was talking about HSI with the internal grant writer for a community college we often work for. This guy is very knowledgeable about federal grants but thought the eligibility for HSI was that his college had to have at least 25% Hispanic students for one year before applying for a HSI grant. His college achieved that milestone at the start of the fall 2014 semester, or around September 1, so he didn’t think they were HSI eligible. A close reading of the RFP sections above shows that he was wrong: as long as the college met the 25% threshold by September 30, 2014, which in this case they did, the college is actually HSI-eligible.

It also turns out that ED does not certify or even maintain a list of HSIs. Instead, applicants self-certify eligibility by signing an assurance. How does a college know whether is has 25% FTE Hispanic students? The students themselves self-certify their “race and ethnicity” at the time of application and these data are aggregated by colleges.

This data gets really murky. Most Americans probably think “Hispanic” is a “race.” Not true, at least by some metrics. Those of us who work with Census data know that the Census definition considers “Hispanic” an ethnicity, not a race. From the Census website: “Hispanic origin can be viewed as the heritage, nationality, lineage, or country of birth of the person or the person’s parents or ancestors before arriving in the United States. People who identify as Hispanic, Latino, or Spanish may be any race.”

In other words, American college students self-certifying as “Hispanic” could have a partial family heritage anywhere from Spain to South America to the Philippines and many places in between. From a Census “race” standpoint, they could be otherwise black, white, Asian, Native American, or multiracial. Combined with immigration and intermarriage, this is why the population of some states, like California and Texas, either are or will be majority-Hispanic. As a practical matter, most IHEs in the southwest and south are likely HSI-eligible already; in a few more years, most IHEs across the country probably will be. This is great news for IHEs, Hispanic students and grant writers!

The above cautionary tale shows why it’s critical to closely read RFPs regarding applicant eligibility and other key factors. When I went through Air Force basic training over 45 years ago, the first class we took was “Rumors and Propaganda.” It taught us not to believe barracks scuttlebutt. The same is true in grant writing.