To view this site you need Adobe Flash Player and your browser must allow javaScripts. Go here to get the latest Flash Player. FUNDING & RESOURCES Protecting the homeland— and the virtue of first responders BY MICHAEL PADDOCK AS YOU MAY HAVE HEARD, WE HAVE ENTERED A NEW ERA OF TRANSPARENCY AND ACCOUNTABILITY . THAT IS CERTAINLY TRUE IN THE CONTEXT OF THEAMERICAN RECOVERY AND REINVESTMENT ACT, WHICH COUNTS TRANSPARENCY AS A PRIMARY GOAL. BUT THESE PRECEPTS ARE ALSO MAKING THEIR WAY INTO GRANT GUIDANCE FOR ANNUAL HOMELAND SECURITY FUNDING PROGRAMS—MOST RECENTLY THE ASSISTANCE TO FIREFIGHTERS GRANT PROGRAM (AFGP). The US Fire Administration (USFA), a ultimately benefit from encouraging cusleader in effective administration of funding tomers to seek grants, will need to change for emergency responders,included specific their tactics, as well. language in the guidance document for the So what is permitted? For those vendors 2009 AFGP that stated that any vendor who who work with state and local first responparticipated in writing, editing, critiquing, or ders, the message is clear: no involvement otherwise preparing an agency’s grant appli- whatsoever in grantwriting—not reviewing, cation would be precluded from bidding on not critiquing, and certainly not writing for subsequent procurement opportunities sup- the grant. However, vendors can (and ported by the grant. should) provide a few necessary elements In other words, the USFA was clarifying that do more to define the project than the and reiterating guidance provided during grant, but ultimately benefit both. the 1990s under various Office of ManageHere are a few do’s and don’t’s in dealing ment and Budget circulars that define how with vendors: federal grant funds may be used by various Do: types of recipients. At the same time,though, Collect published documents that are USFA was also asserting a policy position suitable for broad distribution and not that these regulations would be strictly specific to a particular application, even enforced, where under previous administraif the content of those documents could tions, they had not. be useful in thinking through a grant As with most actions the president and application narrative (like the needs the Cabinet take in the first 100 days after taking solution being offered addresses); office, there is a natural tendency to want to Include vendors in developing a project read the policy potential into every word. In plan,especially providing assistance with this case,however,vendors and grantseeking product configurations and developing a agencies would be remiss to ignore the clear realistic budget for the overall project; indication that the 26 federal grantmaking Ask vendors for information and help in agencies generally, and the Department of identifying public and private funding Homeland Security in particular, will be sources that can support the project; working to make the grantseeking process as Allocate your own resources to grantwritclean and visible as possible. Moreover, the ing, whether internal staff or an outside line that defines terms like “collusion” and grants-specific consulting firm, realizing “conflict of interest” is going to be moved a that it will require resources to apply for a little farther upstream in the funding process, grant; and violations will not be tolerated. Expect vendors to answer your questions The involvement of vendors as trusted promptly; advisors in municipal projects,from defining Keep control of your project, rememberneeds to helping frame budgets, will not, ing that it will be your responsibility to and cannot, go away. As anyone who has implement it once it’s funded. tried to define a major citywide security project can tell you, it takes all the project stakeholders, working hand in hand, to make a Don’t: Ask vendors to write your application for project work. But the times of intensive venyou or accept their help writing an applidor involvement in municipal grantwriting cation (some programs do allow this type appear to be a-changin’, and vendors, who Register online today for exclusive online content and eNewsletters of help, but most of them aren’t in the homeland security area); Submit any grant application that you didn’t drive or whose content you aren’t comfortable with or don’t feel represents your vision for the project; Agree to a percentage of the grant award as compensation for grantwriting, or any other creative compensation arrangement beyond paying a straight,fair fee for the work; Feel compelled to contract with any vendor outside your normal procurement procedures after you receive an award,in exchange for help, support, or information before you apply,and never sign anything to that effect; Let an assertive vendor take your project in a direction that is contrary to your vision. Exceptions—and cautions As with any rule, there are exceptions. Fiduciary agents, which may be non-profit, municipal, or for-profit entities, must apply for grants in the Port Security Grants Program. Research and development grants are often provided to for-profits, which have much wider latitude in dealing with vendors. Despite the gray areas, though, the USFA’s insistence on limiting the involvement of vendors in municipal grant applications provides grantseekers across the homeland security community with an important insight into the policy direction we can expect to see continue through the next four years. For many agencies, it’s a point barely worth noting, but those who have been relying a little too much on vendors to do the heavy lifting in the grantseeking department will need to prepare to take up the responsibility themselves or risk seeing the funding go to those who do. HST Michael Paddock is CEO of Grants Office LLC. He can be reached at MPaddock@grantsoffice.com. Homeland Security Today Magazine | June 2009 9