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Adventures in Bureaucracy and the Long Tale of Deciphering Eligibility: A Farce Featuring the Department of Education’s Erin Pfeltz

There are numerous good reasons why we often make fun of the Department of Education. One recently appeared in the Seliger Funding Report. Subscribers saw the “Charter Schools Program (CSP) Grants to Non-State Educational Agencies for Planning, Program Design, and Implementation and for Dissemination” program in the June 16 newsletter. The eligibility criteria for it, however, are somewhat confusing:

Planning and Initial Implementation (CFDA No. 84.282B): Non-SEA eligible applicants in States with a State statute specifically authorizing the establishment of charter schools and in which the SEA elects not to participate in the CSP or does not have an application approved under the CSP.

So we have two criteria:

1) States that authorize charter schools and

2) That don’t participate in the CSP.

Since it is not abundantly clear which states are eligible, the RFP also lists the states participating in the CSP:

Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Indiana, Kansas, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New Mexico, New York, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Utah, Wisconsin.

Great! But does the Department of Education have a list of those that authorize charter schools and don’t participate? To find out, I called Erin Pfeltz, the contact person, but she didn’t answer, so I left a message and sent the following e-mail as well:

I left a voicemail for you a few minutes ago asking if you have a list of states in which organizations are eligible for the “Charter Schools Program (CSP) Grants to Non-State Educational Agencies for Planning, Program Design, and Implementation and for Dissemination.”

If so, can you send it to me?

She replied a day and a half later, too late for the newsletter:

The information in the federal register notice includes a list of states which currently have an approved application with the CSP (http://edocket.access.gpo.gov/2008/E8-13470.htm). Non-SEA applicants in those states should contact their SEA for information related to the CSP subgrant competition. More information on the Charter Schools Program can be found at http://www.ed.gov/programs/charter/index.html.

I replied with some quotes from the RFP and then said:

The RFP gives us a list of states that do participate in the CSP. My question is whether you have a list of states that a) have authorized charter schools and b) do not have an application approved under the CSP.

In other words, which states do not authorize charter schools?

Erin responded:

States without charter school legislation are: Alabama, Kentucky, Nebraska, North Dakota, South Dakota, Maine, Montana, Vermont, Washington, West Virginia.

And then I responded:

Subtracting those states and the ones that already participate in the CSP program leaves me with NV, AZ, WY, OK, IA, MO, MS, NH, RI, HI, AND AK.

So states from these states and only these states are eligible. Is that correct?

She said:

Eligible applicants from these states would be able to apply.

Notice the weasel words: she didn’t say that the states I listed were the actual and only ones eligible. So I sent back yet another note asking her to verify that and she replied “For the current competition, only eligible applicants from these states would be able to apply.”

Beautiful! Finally! After a half dozen or so e-mails, I extracted the crucial eligibility information. Based on her tenacious and expert obfuscation, she deserves to promoted, possibly to Undersecretary for Obscure RFP Development (isn’t it obvious that I’m only talking about the current competition, not every conceivable competition?).

Wouldn’t it have been easier if the initial RFP simply stated the eligible states? The obvious answer is “yes,” but it also wouldn’t leave room for potential mistakes from the Department of Education. Instead, the RFP eligibility is convoluted and hard to understand for reasons known chiefly to bureaucrats; when I asked Erin, she wrote, “The states are listed in that way to encourage eligible applicants whose states have an approved CSP grant to contact their state departments of education.” Maybe: but that reason smacks of being imagined after the fact, and the goal could’ve been more easily accomplished by just listing the 11 eligible states and then saying, “Everyone else, contact your SEA.” But the Department of Education has no incentive to make its applications easier for everyone else to understand—and it doesn’t.

When I wrote about Deconstructing the Question: How to Parse a Confused RFP and RFP Lunacy and Answering Repetitive or Impossible Questions, I was really writing about how needlessly hard it is to understand RFPs. This is another example of it, and why it’s important for grant writers to relax, take their time, and make sure they understand every aspect of what they’re reading. If you don’t, you shouldn’t hesitate to contact the funding organization when you’re flummoxed.

The material most people read most of the time, whether in newspapers, books, or blogs, is designed to be as easily comprehended as possible. Many things produced by bureaucracies, however, have other goals in mind—like laws, for example, which are designed to stymie clever lawyers rather than be understood by laymen. Such alternate goals and the processes leading to bad writing are in part explicated by Roger Shuy in Bureaucratic Language in Government & Business, a book I’ve referenced before and will no doubt mention again because it’s so useful for understanding how the system that produces RFPs like the one for the Charter Schools Program (CSP) Grants to Non-State Educational Agencies come about and why correspondence with people like Erin can be frustrating, especially for those not schooled in the art of assertiveness.* In grant writing, assertiveness is important because confused writing like the eligibility guidelines above is fairly common—like missing or broken links on state and federal websites. I recently tried finding information about grant awards made by the Administration for Children and Families, but the link was broken and the contact page has no e-mail addresses for technical problems. I sent an e-mail to their general address two weeks ago anyway and haven’t heard anything since.

Were it more important, I’d start making calls and moving up the food chain, but in this case it isn’t. Regardless, tenacity and patience are essential attributes for grant writers, who must be able to navigate the confused linguistic landscape of RFPs.


* Sorry for the long sentence, but I just dropped into a Proustian reverie brought on by RFPs instead of madeleines. Perhaps one of you readers can translate this long-winded sentence into French for me.