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

August 21st, 2011 · by Jake Seliger · 7 Comments

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 Grants.gov—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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