By Chris LaPage
January 2011

A big federal agency just released a new grant that is accompanied by a guidance document filled with 150 pages of content. The guidance document contains all the granular details on the grant program, including instructions for development of the proposal and submission. The guidance document may be referred to by several names, including request for proposals (RFP), request for applications (RFA), and Notice of Funds Availability (NOFA). Based on a quick review of the information, you are considering developing a proposal under this recently released grant program. Considering the size of the guidance document, one would assume that the items and services eligible for purchase with the grant funding are clearly delineated.

In particular, you are looking to fund video conferencing endpoints in order to conduct education/training sessions as well as deliver telehealth services. How do you find out if these expenses are allowable under the grant program? Guidance documents typically have a couple of sections that are an obvious starting point for finding the answer to this question: Allowable Expenses (or Eligible Costs) and Funding Restrictions. If the agency has created a carefully planned program and a well-written guidance document, end-user devices and equipment will be listed either as an allowable expense or a funding restriction.

Unfortunately, even when a list of eligible costs are present, often times the guidance document includes a statement indicating that "all other costs consistent with the purposes of this program, as determined by the Secretary [head of the agency administering the program] are allowable."

In some instances, only funding restrictions are catalogued while specific allowable expenses are mentioned in the context of the generic aforementioned statement. In a few cases, the grant guidance will not mention anything specific and simply limit the amount of technology (hardware and software) that can be included in the request (e.g.- no more than 20% of requested funds can be used to purchase hardware and software).

Considering this ambiguity, how can you be sure that the items/services that you are requesting from a grantor are allowed under the program?

First and foremost, read over the guidance document in its entirety. You may find the answer you are looking for buried in a section of the guidance document that would not make intuitive sense. For example, the reporting requirements section of the grant guidance may contain a statement like "For all video conferencing hardware and software purchased with grant funds, the recipient must document the percentage that these items are used for the project outlined in the proposal." It can be implied from this statement that end-user video conferencing equipment is an allowable expense under the grant program.

If a careful review of the guidance document doesn't turn up an answer, then you should contact the agency staff member assigned to the particular grant program. The contact information will be included in the grant guidance. The staff member may put you on the right track, regurgitate ambiguous details from the grant guidance, or not respond whatsoever. Many federal agencies will post a Frequently Asked Questions (FAQs) section on their website to address common themes that may have been left out of the grant guidance or feedback has indicated as ambiguous. If the program is annual in nature, you can research past recipients and reach out to determine if they were able to include the items you want to include.

Finally, re-examine the priorities and goals that the grant program intends to address. Unless an item is specifically disallowed, it should be fundable insofar as you can make a strong case in the Budget Justification section of the proposal for how it is essential to the project in meeting the goals of the grant program. For example, if the goal of the project is to address health care access issues in rural communities, a strong justification can be made for the use of video conferencing technology in delivering telehealth services to overcome transportation and health professional shortage issues associated with remote areas. In this particular instance, the video conferencing equipment is an essential ingredient to the parameters of the project and the justification is obvious. If the items that you are seeking to include in the budget are ancillary to the project (i.e. non-essential and the justification is a stretch) and the guidance document is ambiguous, then you are better off not to include them considering that it could derail the entire proposal.

In conclusion, while the guidance document is the most important piece you will need in developing a grant proposal, you will be frustrated if you think everything will be addressed in a straightforward manner. When deciding on the specific items/services to include in the funding request, you need to know how to read between the lines and provide solid justification.