I'm really pissed at OHA's grant processUpdate:
I posted the missive below in haste and in
anger, and honestly, I was frustrated by a couple completely unrelated issues
that had me in a generally pissy mood Monday. Something that doesn't happen all
that often, for those who know me. While I do think OHA as a public agency is
fair game for public criticism of their processes, and hopefully some good will
come of having these issues aired, it would have been more professional of me to
contact them directly and raise my concerns before posting them
here.
Part of the reason I responded here was because of the seeming finality of the letter we received, but I have learned that, if we present the reasons why we feel that a decision was made in error, we will be given a fair opportunity for reconsideration, like other organizations in similar situations have been and are. I don't expect to be treated any differently one way or the other because I have made a public issue of this, and I appreciate the opportunity to seek reconsideration for our applications. I was wrong to jump to conclusions without contacting OHA first, and I apologize to Matt and everyone else at OHA who was involved. I also want to clarify, in case it wasn't clear, that although I mentioned that Matt Lorin's name was on the letter, I did not at all mean this to be an attack on him personally. I have heard from several people who I respect who have very good things to say about Matt, as well as his overall efforts to improve the grant program at OHA. I understand that he has in fact made good progress in improving the efficiency, fairness and transparency of the process, for which he deserves credit and support. Although I do think this was mishandled somewhere in OHA's staff, as I said and want to reemphasize, I don't believe it was malicious, but just some bureaucratic mistakes. While OHA certainly has its problems, it is also made up of a lot of hard working people who are generally trying to do the best they can for the benefit of Hawaiians, and we are all working toward the same goals. I am seriously pissed off at OHA right now, and I'm going to vent. And, since I happen to have a platform here, expose what I see as the ridiculousness of their grant process. I have been critical of OHA when I have issues with them, for example in the manner of their pursuit of the Akaka bill; but I have also not hesitated to give them credit where I think it is due, for example through their support for positive programs. In the past, I have expressed both appreciation for the support of their grant program for our Kapahu Living Farm project, while also offering constructive criticism on the timing of their grant process (a grant submitted in April 2005, with a budget that was supposed to start in January 2006, wasn't approved until December 2005, and then the first check wasn't issued until July 2006, halfway into the program year already). At the end of June, the Kipahulu Ohana submitted two grants to OHA, one for the reconstruction of a 36' boat as a community vessel for marine resource management, fishing, education and search and rescue; and the other for invasive species control in the native forest of Kipahulu. I just got both grant packages back, with letters saying "we were unable to consider this request based on incompleteness." They listed four reasons for this. I will take them one by one. 1) "We do not have anyone from your organization listed as having attended an OHA Grants Workshop this past year." In fact, we did have someone attend. Not sure why this isn't listed in their records, but we were not given any opportunity to find out why, or explain that someone had attended. (Update: It seems like what happened is that the person who attended on our behalf was also there for other organizations, and didn't realize she needed to list them all when she signed up. So we did have someone at a workshop, and hopefully we can clear that up, but OHA is not to blame if we weren't listed.) 2) "Other funding and/or in-kind confirmation for all match listed was not included." But their application instructions say: "Applicant is required to provide confirmation of other funding (award letter, contract, etc.) prior to presentation of the grant request to the OHA Administrator or Board of Trustees." Not at the time of submitting the application. And their instructions say: "Submit letters of confirmation from other funding sources as received." OHA says it will take six months to consider a request over $50K, so it would be totally ridiculous to expect a project to raise 50% of the funds, then submit a grant request to OHA, then wait six months for OHA to consider the request—and who knows how long to finally cut a check. Their application instructions actually make sense—submit the application, and then provide the confirmations of matching funds as they come in. But now, contrary to their own instructions, they have rejected the application because "confirmation for all match listed was not included." 3) "No current tax clearance (with State of Hawaii & Federal department of taxation stamps of approval) was submitted." First off, in every other government grant we've received, including previous OHA grants, the tax clearance was required to be submitted by the time the award was actually granted, not submitted along with the application. But I submitted an application for tax clearance back on June 6. Over two weeks later, I got it back from the state saying we had missed one GET filing. But they were in error (not the first time), and after I tracked down the filing, I resubmitted the application. Then a couple weeks later still, I got the application back from the IRS saying there was no 990 filing for 2006. But we had filed our 990 on time in May. I called the IRS office in Honolulu and was told that it takes them 4-6 months to process 990s to show up in their records, but that I could submit a signed copy of our return and they would process it as an original. After another call, they suddenly changed their mind and decided to just go ahead and issue the tax clearance. So I sent them back the form, and finally, almost six weeks after I originally submitted the application, we received our tax clearance, which I promptly sent to OHA to add to our grant file. The reason it took so long was entirely due to errors and delays in the state and federal tax offices. But nope, no tax clearance submitted with the grant application, and OHA rejects it outright. If a small grassroots organization like ours, with one part-time administrative staff person, doesn't submit a tax clearance application six weeks in advance of the grant deadline just in case the state and feds screw up, too bad, fuck you, out of luck. 4) "The IRS non-profit tax-exempt status letter advance ruling period ended on 12/31/99." Maybe it is my fault because I didn't submit the letter from 2000 referring to the original letter saying "That letter is still in effect." But this same letter has been submitted for every grant we have received, from state, county and private foundation sources, including OHA, for the last five years that I've been submitting grants. This is the first time anyone has rejected a grant based on the IRS letter. OHA listed all four of these reasons for rejecting our applications, but I assume they would have rejected it for any one of the four reasons. These are all tiny technical issues. #1 seems to be a problem with OHA's own records (or could easily be clarified). #2 is just inconsistent with their own instructions. #3 is due to the state and federal tax offices. #4 is inconsistent with every other grant I've ever submitted (and also easily remedied). Who the hell set the policy at OHA to reject grants outright for these manini technical reasons? And how many other otherwise really good grants requests are being rejected? Honestly, I would like to know the answer to these questions. I'm sure it is all some well-meaning bureaucratic decision, not some malicious intent, but it is, in my humble opinion, stupid and counterproductive. (Matthew Lorin, Director of Planning, Research, Evaluation and Grants, signed the letter, but I have no idea whether he is responsible for the policy.) I'm pissed personally because I put a lot of time into these grants, and this affects projects that I think are very important (and yes, my own source of livelihood for the small portion of the budget I would get for administering the grants). OHA not even considering the grant requests for manini technical reasons means more of my time trying to stir up funds from other sources for what I'm sure OHA considers otherwise very worthy projects that are totally supportive of their mission. And maybe we'll get funds elsewhere, though probably delayed. Meanwhile, invasive species will continue to creep up the mountain unchecked in Kipahulu, one of the most precious and endangered native forest areas in the islands. And East Maui's ocean resources continue to be under pressure, sure to substantially increase when the Superferry starts running. But the big picture here is OHA's mission overall. They are supposed to be helping Hawaiians, and through the grant program funding organizations that are doing good work in the Hawaiian community, benefitting Hawaiians. They have funded some great programs. Does it really serve their mission to reject every grant application, no matter how otherwise worthy, that has small technical issues that could easily be either cleared up or corrected? It seems to me they would want to show the slightest flexibility to allow grassroots Hawaiian organizations whose grants are otherwise perfectly good to fill in small details that might be missing, or in doubt, or out of their control. It seems like they would want to actually support organizations in making sure their grant applications meet their criteria, instead of being hard-asses and outright rejecting any grant that has one little hair out of place. And it seems like their criteria for completeness should be consistent with their own instructions! I don't know what else to say. I feel like reaching over into the OHA office and shaking someone and saying "What the hell are you thinking??!!" But I'll just rant here, and hope that some folks at OHA read this and realize how stupid and inconsistent and counterproductive their policy is, and that others will read it and put some pressure on OHA to realize how stupid and inconsistent and counterproductive their policy is. And maybe, when their next grant cycle rolls around next year, they will reconsider how to really serve small grassroots Hawaiian organizations, and the Hawaiian communities they serve, that are supposed to be the beneficiaries of their grant program. Posted: Mon - July 23, 2007 at 07:54 PM |
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