Tag Archives: OMB

Searching for Talent Search: Where Oh Where Has the Talent Search RFP Gone And Why is It A Secret?

UPDATE: Talent Search has finally appeared, and the RFP vindicates much of what Isaac wrote below.

Having been in business for over 17 years, Seliger + Associates has lots of spies. Well, not spies exactly, but clients, former and current, program officers and assorted grant cognoscenti who send us interesting nuggets. Recently, one made it into “Be Nice to Your Program Officer: Reprogrammed / Unobligated Federal Funds Mean Christmas May Come Early and Often This Year” about the anticipated release of the Talent Search RFP.

A client for whom we wrote a funded proposal for a different TRIO program let us know that the “Draft Talent Search Application” was hiding in plain sight at Bulletin Board of an organization called the Council for Opportunity in Education (COE). Even though I’ve been writing TRIO proposals since the early days of the Clinton administration, I’d never heard of COE, which turns out to be more or less a trade group for TRIO grantees and wannabes. Our client hangs out at COE gatherings and told us about the draft Talent Search RFP, since we’re going to write the proposal for her nonprofit. I din’t bother reading the draft RFP because only the final published document matters.

What was intriguing, however, was that the draft Talent Search Application indicated that the real RFP would be issued on October 22. Astute readers might realize that it’s now Halloween. So what happened?

To investigate on behalf of our client and curious Grant Writing Confidential readers, I sent an e-mail to Julia Tower, the contact person listed on the COE website for Talent Search, on October 23. The draft documents were apparently kicked over to COE by the Department of Education, much like YouthBuild stuff is often kicked over to YouthBuild USA by the Department of Labor. Anyway, my e-mail to Julia went out on October 23 and asked innocently (I know it’s hard to believe, but I can be sweet at times) if she knew when the Talent Search RFP would actually be published and if she knew the reason for delay (I can guess the reason, which I reveal below—wait for it—but wanted to back check with somebody actually “in the know”).

Julia sent me a reply, typos and all, that said: “The ED source for all TS info- regs were published- draft appl for grants available on web site eventually- & at ED free wkshops now.” I love “free wkshops” as much as the next guy, but I replied by reiterating my query because Grant Writing Confidential readers presumably want to know if she knows when the RFP will be published.

Julia again ignored my pointed questions and replied, again with typos, “Is your company an institutuional member of coe?” I wrote back:

We are not COE members, but why does this matter?

As bloggers, we sometimes act as journalists. You may wish treat my inquiry the same as if it were coming from a NYT, WP or WSJ reporter, since it is possible I may use this exchange in a blog post. Are the questions I’m asking proprietary in any way or is it not public information? If it is not public information, why is it a secret? A “no comment” or decline to comment might strike our readers, who number in the thousands, as evasive.

FYI, as a grant writer, I can assure you that a draft application and workshops are useless. What matters is the published RFP and the deadline. If I write the post, I’ll explain why.

Since then, I haven’t heard from Julia or anyone else at COE, and, as of this writing, the Department of Education still hasn’t published the Talent Search RFP. Since they have now missed the publication date by at least 10 days and are supposed to provide applicants at least 45 days to respond, the proposed proposal submission deadline of December 9 will also probably be stretched out by at least 10 days, putting it around December 20. Oops, that’s a bit close to Christmas, which might push the deadline into January and smack into the FY 2011 budget hurricane that was the subject of my original post. Funny how grant writing things that come around, go around.

Note to Julia—a draft application and pre-application workshops are fairly useless from a grant writer’s perspective because the only document that really matters is the RFP/application as published in the Federal Register and/or grants.gov. The rest is merely speculation and isn’t binding. I also can’t imagine why the Department of Education flies Program Officers all around the country for these workshops, which could easily be presented on the web as podcasts or what have you. It seems the TRIO office at the Department of Education is firmly cemented in the last century.*

Now, for my guess regarding the delay: It is probably a result of the giant backlog at the White House Office of Management and Budget (OMB). The OMB has to approve all RFPs, regulations and other federal announcements prior publication. With the current avalanche of RFPs, as well health care reform and Wall Street reform rule making going on, I suspect the boys and girls at the OMB are probably a wee bit behind. In addition to Talent Search, we’re also waiting for HRSA to issue their FOA (Funding Opportunity Announcement, which is HRSA-speak for RFP) for the Expanded Medical Capacity (EMC) program. Another our spies said the EMC FOA is hung up at the OMB, and I suspect it’s probably sitting on top of the Talent Search RFP on some GS-11’s desk.


* In the early days of our business, I actually sometimes went to RFP workshops, but not to listen to the blather and giggling of the Program Officers (go to any such workshop and the presenter will eventually giggle when confronted with an uncomfortable question). I went to market our services, wearing a Seliger + Associates “WE KNOW WHERE THE MONEY IS” t-shirt and passing out marketing flyers.

This typically drove the Program Officers over the edge. I was actually almost arrested at a Department of Education TRIO workshop on the campus of Seattle Community College around 1995. When the Program Officer figured out what I was doing, she called campus security. The President of the College promptly showed up with an officer or two in tow and demanded to know what I was doing. I said I’m simply drumming up business and exercising my free speech rights. He huffed and puffed and left me to pass out flyers and chat-up the attendees.

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.

It’s a Grant, Not a Gift: A Primer on Grants Management

I was in LA over Labor Day weekend and, at a pool party, chatted with a semi-retired CPA who has been hired by a large nonprofit hospital to help with an audit of a federal grant. The audit is being performed under the Office of Management and Budget (OMB) Circular No. A-133. OMB publishes a variety of circulars covering all sorts of topics. Some, such as A-133, are of great importance to nonprofit and public agency grant recipients but are routinely ignored (to the great peril of the agencies).

In the case of the LA hospital I discussed over daiquiris*, the organization was so surprised and elated at getting the grant that they treated it like a Christmas present. In other words, even though the hospital is a multi-million dollar operation with a full-fledged accounting department, they completely failed to follow federal accounting rules in implementing the grant. They spent the money more or less without regard to terms of the RFP and did not follow A-133 requirements. When faced with the prospect of an unsmiling federal audit team and an unflattering story in the LA Times, they brought in a knowledgeable CPA to straighten out the mess.

The issue resonates with me because, in addition to writing more proposals than I care to think about, I’ve also had the thankless task of managing numerous grants. My favorite story about grant management concerns a large Department of Energy project for electric cars during the late 1970s that I wrote when I worked for the City of Lynwood. This long-forgotten program gave the city about $1 million to buy and operate ten electric vehicles, which proved to be slow and unreliable, making them perfect for a municipal fleet. We were unlucky enough to be selected for an audit and I got tagged to handle it. The auditor turned out to be from the Department of Defense, since the newly created Department of Energy was too fresh to have its own auditors. I settled the fellow down in a conference room with donuts, an essential tool for all audits, and he asked his first question: “What product do you produce in this facility?” Since we were at City Hall, I smiled and responded: “Promises.” The audit went downhill from there.

Based on that experience and many others, here are some basic tips on managing grants:

  • If you don’t have a finance director familiar with grant accounting, find an outside accounting firm that is and hire them to set up your grant-related accounts and procedures.
  • Make sure the person responsible for managing the grant has obtained, read and understands the relevant regulations, including OMB Circulars for federal grants.
  • Spend the grant funds as quickly as you can, since funders don’t want the money back. If an agency fails to spend a grant and returns the funds, the funder will be very unlikely to award another grant.
  • Make sure the funds are spent in accordance with the grant agreement. It is important that the agency can show “maintenance of effort,” meaning that whatever was being done before is not being reduced following grant receipt and that the agency is not supplanting existing funds with grant funds. For example, if the grant is for after school programming, it is not okay to use the grant to pay for current after school programming so that the District Superintendent can remodel her office. If an audit disallows expenditures, the agency will have to pay the money back, which is not an attractive prospect.
  • Keep accurate records, including expenditures, personnel records, activities and in-kind support. That’s right, if you’ve included in-kind support as a match in the budget, you may have to prove that it was provided, so keeping track of volunteer hours, value of referral services provided, etc., is essential. Even innocent and detailed records can cause problems during an audit. For example, while serving as Development Manager for the City of Inglewood**, I had to handle an audit for an Economic Development Administration (EDA) grant. The grant involved demolition, which meant Davis-Bacon prevailing wage requirements for all persons paid through the grant. When the auditor began pulling expenditure records (for each expenditure, this means a check request, purchase order and cancelled check) for workers, it turned out that every demolition worker had the same address, which was a check cashing store. The contractor was apparently having the workers cash their checks and return a good portion of the so-called “prevailing wages” the workers were supposed to receive to the contractor. To avoid disallowance of costs, we had to chase down the contractor once we figured this out to get him to provide back pay to a whole bunch of suddenly very happy demolition workers.

The secret to grant management is to remember that everything related to a grant is likely public information, so don’t do anything you wouldn’t mind seeing on the front page of the local newspaper. As long as you think your grant-funded trip to Las Vegas will pass the smell test for having something to do with solving the challenges facing at-risk youth being funded by a Department of Education grant, I say, Viva Las Vegas!. Just keep in mind, that, when it comes to grants, what happens in Vegas may not stay in Vegas.


*I’m talking real Hemingway “Papa Doble” daiquiris, not the disgusting pre-made concoctions found in most bars.

** As Tupac said and as quoted previously, “Inglewood always up to no good.”