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Program Officer Blues: What To Do When The RFP Is Ambiguous, Contradictory, Incoherent, or All Three

When you find an ambiguity or outright contradiction in an RFP, it’s time to contact the Program Officer, whose phone number and e-mail address is almost always stashed somewhere in the RFP. The big problem with contacting a Program Officer is simple: you can’t trust what she or he tells you. The formal RFP—particularly if published in the Federal Register and/or—takes precedence over anything the Program Officer tells you. Unless you’re given a specific reference to instructions in the RFP, you can’t safely rely on advice given by a Program Officer. This is the primary reason we see no point in attending bidders’ conferences, or, more likely these days, watching “webinars” about RFPs. Anything said in those forums that isn’t backed by the RFP, program guidelines, and/or the underlying section of the Code of Federal Regulations (CFR) means jack.

And that’s assuming you even can get advice from Program Officers. A client recently wanted more detail about a slightly ambiguous outcome requirement in the Pathways to Responsible Fatherhood proposal we were writing, so we advised her to contact Tanya Howell, the ACF staffer assigned to the program. Our client asked two questions, and in both cases Ms. Howell began by responding with the same helpful sentence: “Applicants should use their best judgment in determining whether they are able to meet the requirements contained in the Funding Opportunity Announcement (FOA), whether they are able to develop an application they believe to be responsive to the FOA and in designing and writing their applications.”

“Applicants should use their best judgment” is another way of saying, “I have no idea, do what you want, and if the reviewer dings you don’t come back and blame me.” Her second sentence, in both cases, said that the measures in question were “at the discretion of the applicant.” This kind of non-answer answer that leaves the applicant in the dark and is only marginally more helpful than no answer at all. It also smacks of the Program Officer simply preparing a template response to questions and applying the template in order to minimize her own need to work.

Here’s another weird example. We recently completed a WIA job training proposal for a large nonprofit in Southern California. The RFP was issued by the Workforce Investment Board (WIB) for a particular jurisdiction, and the RFP specified that applicants must demonstrate a written collaboration with Workforce Sector Intermediaries. We’d never seen this term before; it was not defined in the RFP and a Google search returned us to the RFP. Since the client is already a WIA grantee, we had our client contact call their Program Officer. The Program Officer also did not know what was meant by Workforce Sector Intermediaries and could not get an answer from her supervisors. In other words, nobody at the WIB knew what was the meaning of a requirement specified in their own RFP.

Still, if you can find a contradiction in an RFP, you can sometimes get a correction issued. We’ve found contradictions at least a dozen times over the years, and sometimes we’ll point them out to Program Officers and get the RFP amended. That’s the only real way you can trust that your interpretation is correct, instead of an example of your “discretion” that might cause you to lose points. Thus, despite the depressing anecdotes above, you should pose your conundrum to the Program Officer.

Clients will also ask us about possible ambiguities, and we give the best answers we can. But clients regularly ask us questions about RFPs that we can’t answer. It’s not that we’re opposed to answering questions, of course—but the questions themselves sometimes can’t be answered by the RFP. At that point, it’s time to call or write the Program Officer and hope for the best.

Before you do, however, you should read the RFP and any associated guidance or CFR reference as closely as possible. That means looking at every single section that could have a bearing on your question. If you’re reading an RFP, you’re basically performing the same exercise that (good) English professors do to novels, poems, drama, and short stories, or that lawyers do to legislation and court decisions: close reading. You can find lots of “how to” guides for close reading from Google, or you can look at one of the original textbooks about close reading, Understanding Fiction. But close reading at its most basic entails looking at every single word in relation to other words and ascertaining how it forms meaning, how meanings of a text change, and what meanings can be interpreted from it. For example, if you were close reading this passage, you might look at the phrase “at its most basic” in the preceding sentence and say, “What about its ‘least’ basic? What do advanced forms of close reading entail?” and so forth.

In Umberto Eco’s Reflections on The Name of the Rose, he says that a novel is “a machine for generating interpretations.” The same is true of other kinds of texts, like RFPs, and your job in close reading is to generate the interpretations to the best of your abilities. Our skills at doing this are, of course, very finely honed, but even those finely honed skills can’t produce something from nothing. We read as closely as possible, use those readings to write a complete and technically correct proposal, and move on to cocktail hour at quittin’ time.

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Juggling Rules and Principles In Running Grant Programs

Grant programs are not based solely around rules (e.g. you must do this, you must not do that) or around guiding principles (e.g. you’re to help the medically indigent achieve better access to healthcare). Neither approach is absolutely correct, and preferences for each tend to go in cycles, like those of leniency and harshness in criminal justice. The question is which you should adhere to, and the more general answer is: rules when you write the proposal, principles when you run a program.

This post again gets at some of the ideas behind the trade-offs inherent in running grant-funded programs, as I discussed in More on Charities and alluded to in Foundations and the Future. Isaac dealt with part of the issue last week, in It’s a Grant, Not a Gift: A Primer on Grants Management, which discusses the absolute rules of budgets. Within those rules, however, there is room for interpretation: how much of the budget travel should be allocated in travel costs, and how much within that should be dedicated to local travel, for example? Renting a Ferrari for the Program Manager probably won’t cut it, but a reasonable mileage reimbursement rate for an appropriate number of miles, given the size of the service area, probably will. If you reshuffle your budget categories by under 10% of the total budget, your Program Officer likely won’t care, but if you decide after the fact to charge 90% of the Executive Director’s time to the project and you’re audited, the auditors very much will care.

One can see the specific issues between rules and principles in novels, as when a character in Orhan Pamuk’s My Name is Red says, “Now that I’ve reached this age, I know that true respect arises not from the heart, but from discrete rules and deference.” The problem is that strict adherence to the rules of governing a particular grant program might actually result in inferior service: you can blindly continue an activity that is ineffective or, perhaps worse, run a program with a flawed project concept. Too strict adherence to principles can cause a different set of problems: they might be the wrong principles, or, worse, the unintended use of grant funds might constitute fraud.

The easy answer is, “find a happy medium,” which isn’t of much practical use when deciding what programs to apply for and how to fund an organization. The tension between rules and principles will probably always exist, like the tension between the orthodoxy of a movement and the reformers of a movement will always exist, regardless of the movement. In The Name of the Rose, much of the conflict revolves around schisms between ecclesiastical orders that question whether or not it is right to live in poverty. This, incidentally, is similar to questions of whether nonprofits should use more of their funds for direct services at the expense of making it easier to, say, attract good people, or whether they should allocate more to administrative expenses as a way to provide better services. Rules might dictate this—or principles. Regardless of which does, those who seek simple solutions to complex problems are often wrong and often have little sense of history between the complex problems in the first place. Both the movement toward rules and toward principles can be a good thing. Too many rules are stifling, and principles that are too general can lead to abuse.

So what should you do, the person who actually runs grant programs? Should you follow what seems best regardless of rules or adhere strictly to what a program orders you to do? There is no answer—there are only particular situations that might arise as a consequence of applying to some programs rather than others, but if you have some idea of the trade-offs involved, you’re going to be better equipped to understand the issues before you. You’ll also be better equipped to understand which programs you should apply for and how you should use what money you earn.

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Evoke The Wonderful Past in Your Needs Assessment

In Umberto Eco’s fabulous The Name of the Rose, Adso of Melk says that “In the past men were handsome and great (now they are children and dwarfs), but this is merely one of the many facts that demonstrate the disaster of an aging world. The young no longer want to study anything, learning is in decline, the whole world walks on its head […]” The novel was published in 1980 and is set in 1321.

In Orhan Pamuk’s My Name is Red, Black says: “A cleric by the name of Nusret […] had made a name for himself during this period of immorality, inflation, crime, and theft. This hoja, who was from the small town of Erzurum, attributed the catastrophes that had befallen Istanbul in the last ten years […] to our having strayed from the path of the Prophet.” The novel was published in 2001 and is set in the 1590s.

In the HBO show The Wire, a police commissioner—Herb, I think, but trying to remember the characters’ names is like trying to learn Russian—says in episode three or four, “It’s not like it was.” That’s the theme of the entire fifth season, which is set at a newspaper. Given that newspapers and TV news stations laid off about 25% of their staff from 2001 to now, and seen similar circulation declines, it’s definitely not like it was.

All three stories demonstrate beliefs about a superior golden age; we’ve been expelled from the Garden of Eden and the present day is one of monstrous vice, corruption, incompetence, mendacity, bad pop music, dissolute youth, depravity, environmental degradation, inappropriate fashion, and the like. Characters in novels, like their counterparts in nostalgic movies, promote this idea. It’s a narrative assumption that often goes unchallenged in newspapers. It’s such a cultural commonplace that it should be a corollary of Writing Needs Assessments: How to Make It Seem Like the End of the World: argue that the past was often better than the present. We used to live in an age of abundance, happiness, and success. Now we don’t. But if you fund our program, we’ll live happily again. All you need to do is cut the check for the program we’re going to run. Your needs assessment needs appropriate data, of course, but it should also have an overarching story. The fall from a golden age could be one such arc.

Recently, the New York Times quoted Plato in “Generation You vs. Me Revisited“: “’The children now love luxury,’ Plato wrote 2,400 years ago. ‘They have bad manners, contempt for authority; they show disrespect for elders and love chatter in place of exercise.’” For more than 2,000 years, and probably longer, we’ve been telling ourselves about a past that probably never existed. (Although I should note that the NYT article questions conventional wisdom and the idea that self-absorption can be measured through tests like the Narcissistic Personality Inventory. Isaac wrote a post about why self-esteem measurements are silly and used similar reasoning to what’s in the article. The underlying phenomena is similar: it’s very hard to ascertain what people think and feel because the only methods of measurement we have are words and behaviors, which are at best imprecise.)

Back to the main point: the idea of a fall from an ideal state is a very old one—at least as old as the Old Testament and probably older. People like it, so you can claim that you need to operate the program you wish to run as a way of recapturing this past, which is much more wholesome than a degraded present beset by all manner of ills, such as gangs. The worse you can make the present appear, the more you need funding. Then, in activities section (or whatever it happens to be called), you should depict the program you wish to run as a way to return to or surpass this state and create a better vision for the future.

This isn’t the only possible approach; you could also frame the issue by arguing that the past has always been as bad as the present: for generations, the target neighborhood/group/city has been mired in poverty, assailed by outsiders, ignored by the government, and harmed by pernicious societal forces. Now, a program has finally come along to remedy the malady and restore the rightful social order, as one might in a traditional Romance (i.e. one with magical events, ordained heroes, and perilous quests).

Either way, the present isn’t good, and the agency applying will be the knight in shining armor ready to slay the social beast, be it crimes, gangs, teenagers more generally, or a dragon infestation. Many writers include elements of the Wonderful Past unconsciously. We’re giving you permission to make the wonderful past an explicit part of your needs assessment.