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Be Nice to Your Program Officer: Reprogrammed / Unobligated Federal Funds Mean Christmas May Come Early and Often This Year

October 18th, 2010 · by Isaac Seliger · 3 Comments

I hope faithful readers who are also federal grantees have been nice to their Program Officers, because this could be the year that Christmas comes early and often.

I recently wrote about the unfolding FY 2011 federal budget fiasco. While cruising in the droptop to Palm Spring this weekend to visit relatives, I got to thinking about the next step: what happens when the Republicans win control of at least one house of Congress? Regardless of one’s politics, this looks certain. We’ll have a lame-duck Congress for a few weeks, during which a budget is unlikely to pass, and then an all-out political brawl when the new Congress starts fulminating on January 3. I’m guessing that the budget won’t get resolved until around March, which means the feds will probably operate under Continuing Resolutions for another three to six months.

If you have a direct federal grant and have been a good boy or girl this year by obligating your grant funds, filing timely reports and doing more or less what your grant agreement calls for (e.g., offering family support services but not leasing Porsches or going on site visits to Bimini), Santa may drop in. Provided that the stars align perfectly by having a full-scale budget rumpus unfold, preventing budget adoption by the lame duck congress, the political appointees who run federal agencies (e.g., the Under Secretary of Education for Undersecretarial Affairs) will quickly realize that they need to spend existing budget authority under their Continuing Resolutions ASAP or risk losing the money when the Federal budget is finally adopted.

In some cases, this will mean hurried-up RFPs processes, like the Department of Treasury’s CDFI program, HUD’s Healthy Homes Production Production Program (open, but with short deadlines), and the Department of Education’s Talent Search program (expected to be issued 10/22 with a deadline of 12/9—see theDraft Talent Search RFP for a glimpse of Days of Future Passed.* In other cases, however, the Program Officer may skip the RFP process entirely, however, and request applications from existing grantees. If you are a grantee, don’t be surprised if you get a call or email from your Program Officer in the next few weeks or months asking for a proposal with a week or two turnaround. While you’ll have to submit a technically correct proposal and be willing to accept whatever offer is made, you’ll have no competition. Just submit the proposal, sign the contract, and off you go!

In addition to trying to spend existing budget authority, Program Officers also sometimes have returned grant funds they need to “re-program.” This happens when a grantee screws up their grant, and, assuming that the grantee hasn’t obligated (there’s that word again) their funds, the Program Officer cancels the contract and takes the unobligated money back. To avoid losing the money when the next budget arrives, the Program Officer will sometimes unload the funds on another grantee she likes.

We wrote a funded HUD Lead-Based Paint Hazard Control (LBPHC) Program grant in the FY 2009 funding round, which was one of only about 30 grants awarded. Last week, I was talking to this client, and he told me that one of the other grantees had already had their grant pulled because of inactivity. The grantee simply couldn’t get their program launched and the HUD Program Officer lost patience. This gives the LBPHC Program Officer another $2 or $3 million for re-programming. I told our client to be ready for the re-programming call—and so should you!

I’ve experienced the joy of re-programming a few times before I was a consultant. When I was Development Manager for the City of Inglewood in the 1980s (per 2Pac, “Inglewood always up to no good”, I wrote about $20 million in funded FAA grants to support redevelopment under the city’s Airport Noise Control and Land Use Compatibility (ANCLUC) program. This was during the Reagan/Congress budget battles and I was invited to submit a last minute ANCLUC proposal once or twice when my Program Officer got the shanks (note for non-golfers: this is different from “being shanked” in prison).

I’ve heard similar tales from clients and others over the years. Between re-programmed funds and the irresistible urge of Program Officers to shovel money out before the budget door slams shuts, a perfect storm for multiple Christmases is brewing. If you get such a call and feel like sharing, post a comment and we’ll keep you anonymous. Let the grant holidays begin.


* This over-the-top pretentious Moody Blues concept album reminds me of my early grant writing days, as I listened to it about a thousand times in 1970s while I scribbled proposals on to seemingly endless legal pads—not an iPad.

Tags: Budgets · Government · Nonprofits