Grant Application and Program Establishment
Program establishment is one of the most important stages in administering federal funds because it is the foundational step from which all the other processes will follow. Creating a well-structured and financed administering agency with defined roles and responsibilities, either through executive order or statute, will be critical for success. As well, the agency must be knowledgeable about the federal laws, terms and conditions which govern the various grant programs which it will apply for and administer. And, it will need leaders and staff that understand those laws and conditions, as well as the needs, priorities and objectives of the applicant(s), in order to translate those into a well-designed application.
Developing the Application
Concept Paper and Staffing
Some states request a concept paper before inviting applications. The advantages are obvious for a large state, but there are some inherent liabilities, and most notably, increased staff effort and potentially delayed funding. Further, if the sub-grant process is using an advisory board, there may be increased demands upon that group of individuals who may be serving voluntarily. Ultimately this is a decision that the SAA must make as to each individual funding process. If a very large number of applicants are anticipated, it may be wise to consider this process as it may narrow the number of organizations invited to invest the time and effort in preparing a more extensive proposal. Each state, staffing pattern, time consideration and board methodology is different. The SAA should review both methodologies with appropriate staff before making this commitment.
Although we highlight traditional application processes here, the SAA should be aware of the positive trend toward e-grants. At this writing some states, including Wisconsin’s Office of Justice Assistance are implementing e-grants systems with varying levels of success. As e-grants systems are refined and as potential applicants become more familiar with them, this section will be altered. Regardless of what method of application your state uses, the application must contain a number of essential elements. At a minimum these should include:
- Statement by the agency of the nature of the funds;
- Type of application (i.e., continuing, initial, emergency funding, etc.;
- Name, address, and federal ID number of the applicant, the project director and financial officer;
- Summary statement outlining the project, including any applicable match;
- Detailed project budget and a full budget narrative, delineated by fund source;
- Anticipated funds requested;
- Recipient agency’s current annual budget;
- Statement of particular purpose areas, either federally required or state-mandated to be addressed;
- Problem and needs statement;
- Summary of accomplishments (if a continuation application);
- Project plan;
- Description of proposed project assessment and evaluation; and
- Authorized signatures of the applicant(s).
As SAA you may also want to require additional application materials, particularly from non-governmental applicants. These might include:
- A copy of the agency’s most recent audit;
- Articles of Incorporation, By-Laws and Board of Directors List; and
- Evidence of IRS tax exempt status.
Some SAAs, such as the Utah Commission on Criminal and Juvenile Justice and the Massachusetts’ Executive Office of Public Safety, also provide written technical assistance to guide less experienced grant writers through the proposal development process. The Ohio Office of Criminal Justice Services has even included a sample grant proposal on its website. Although you may presume sub-grantees have the knowledge needed to write a successful grant, technical assistance, including an applicant conference; or tips on grant writing can be extremely beneficial. The importance of clarity in the application process is obvious. In many areas it may be advisable to consider a bilingual process to help ensure diversity of applicants and an inclusive programmatic scheme. Regardless, the application requirements must be comprehensive enough to ensure a quality award, but not so very complex that potentially worthwhile applicants are excluded. This balancing process requires the attention of key staff and the judgment and decision of the SAA herself.
See the Delaware Criminal Justice Council and Pennsylvania Commission on Crime and Delinquency for additional examples.
Whether a concept paper method is used or not, it is essential to use clearly reasoned and pre-defined review criteria. If an advisory board is involved in the final decision process it is important for them to have been involved in the creation of the criteria. First and foremost, the agency must be objective when making funding decisions. This fundamental fairness is for the benefit not only of the applicant agencies, but also that of the SAA itself. Further, these criteria may take on great importance if a particular applicant decides that it has been treated unfairly and decides to invoke administrative or judicial processes. The criteria should rely heavily on the purpose areas defined by the federal funding agency and those developed by the agency staff, the advisory board (if applicable), and the SAA herself. Once developed for a particular funding process they should not be altered during the decision making process. A static process is crucial to ensure fairness throughout the application process.
equally important as clear and concise review criteria is the use of qualified reviewers. In addition to understanding grant processes, reviewers should possess field operations experience in order to effectively review the applications and make sense of them. For example, individuals reviewing applications for a gun violence reduction initiative should have some understanding about police work as well as grants processes. Reviewers should also be encouraged to look beyond pretty packaging, fancy binders, and flowing prose to search for really good programs and initiatives; some small organizations, especially small to mid-size police departments, do not have full time grant writers, but are able to articulate and propose a response to a significant need.
Award Document/Denial Letter
The award document must likewise be carefully drafted. The amount of the award must be clearly stated. Equally important from a legal perspective is the inclusion of the specific grant conditions, including any special conditions that are to be adhered to. Reporting periods, expectations of the grantor (e.g. financial reports, site visits) should also be included in this document. Likewise, match expectations should be outlined and the duration of the grant reiterated. Often the award will be in an amount far less than had been requested. Whenever this occurs, the award letter should state the rationale for the lesser amount. A statement that sufficient funds were simply unavailable to fund the applicant’s entire plan will often suffice to protect the agency.
Denial letters present a greater challenge. Here reliance upon the objective criteria discussed above is particularly critical. Negative comments concerning the applicant agency or its application should be avoided. The SAA should be mindful that a thoughtfully worded denial letter may prevent litigation and will always enhance the credibility of the agency.
Terms, Conditions and Special Conditions
Terms and Conditions common to all grant recipients as federally required (e.g. EEOC, drug free workplace, etc.) or state-mandated, are usually described in the application section and/or with the award document. As the grantee, you may play a significant role in the development of special conditions for your subgrantee projects. The difference being that the special conditions are specific to the project(s) that are being funded by the subgrantee agency.Other special conditions include requirements for subgrantees to submit copies of sole source procurement requests to the SAA in advance of final acceptance of a contractor and/or execution of the contract; another special condition may be to require that the subgrantee revise financial or programmatic information in the application before obligating any grant funds for the project. Once developed, compliance with the special conditions is as important to the grantee agency as are the terms and conditions that are passed down from the federal awarding agency to the grantee and in turn, to the subgrantee. Failure to comply with a special condition is egregious and should be considered as cause for withholding current or future funding until full compliance by the subgrantee. For examples of special conditions, see the Colorado Department of Public Safety website.