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	<title>Comments on: Social Innovation Fund Process Draft</title>
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		<title>By: Adin Miller</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8443</link>
		<dc:creator>Adin Miller</dc:creator>
		<pubDate>Wed, 06 Jan 2010 23:34:19 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8443</guid>
		<description>My sense is that the Corporation fis really torn on the concept of funding true innovation versus proven impact. The draft guidelines -- in echoing the Department of Education&#039;s i3 program -- emphasize &quot;strong impact&quot; and three levels of proven evidence (strong, moderate, and preliminary). But even the preliminary level is based on research evidence, which skews the balance in my opinion toward the proven impact side. As Michele Jolin, of the White House Office on Social Innovation, mentioned at least year&#039;s National Conference for Volunteering and Service, government is not best at taking risk and the SIF is the perfect example of a program that should be taking risks. My hope is that the Corporation finds a path that does allow its intermediaries to support true innovation.</description>
		<content:encoded><![CDATA[<p>My sense is that the Corporation fis really torn on the concept of funding true innovation versus proven impact. The draft guidelines &#8212; in echoing the Department of Education&#8217;s i3 program &#8212; emphasize &#8220;strong impact&#8221; and three levels of proven evidence (strong, moderate, and preliminary). But even the preliminary level is based on research evidence, which skews the balance in my opinion toward the proven impact side. As Michele Jolin, of the White House Office on Social Innovation, mentioned at least year&#8217;s National Conference for Volunteering and Service, government is not best at taking risk and the SIF is the perfect example of a program that should be taking risks. My hope is that the Corporation finds a path that does allow its intermediaries to support true innovation.</p>
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		<title>By: Michael Edwards</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8442</link>
		<dc:creator>Michael Edwards</dc:creator>
		<pubDate>Tue, 05 Jan 2010 23:16:55 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8442</guid>
		<description>Thanks for the invitation to comment on the Social Innovation Fund, though my first reaction is whether to laugh or cry – trillions of dollars with almost no strings attached to bail out Wall Street and $50 million for civil society surrounded by bureaucracy and micro-management by numbers? It’s not just the amounts that are derisory, but the fact that the mechanisms involved are so lacking in, well, innovation. These are the same ideas that we know don’t work if you really want social change -empowering distant intermediaries, increasing the number of hoops that groups must jump through, and investing scarce resources in number-crunching in lieu of real evaluation. The whole scheme is implicitly biased towards those who speak the language of the “new philanthropy” and the service-delivery efforts they support, but there’s no evidence that these approaches make the biggest impact on what matters most – the structural and systemic problems in society that hold so many people back. Wouldn’t more investment in tackling those problems be “social innovation?”
 
For example, the call for &quot;rigorous evidence&quot; excludes evidence that is rendered rigorous by means other than experimental design and randomized trials (p11 and p15), despite the documented weaknesses of these methods and the strengths of alternatives like action-research. Any activity which cannot be subjected to these methods will be excluded. That means most things are key to long-term social transformation.
 
Providing for only 5 per cent for administrative costs and insisting on an equal financial match will privilege cash-rich intermediaries who may not be the best-equipped in program terms (i.e. those with their ear closest to the ground, or those who are best at supporting smaller organizations with non-financial help). The usual suspects will win, and their biases will be replicated throughout the system. And one could go on.
 
Perhaps we should run a sweepstake on who will get resources from the Fund and publish the results? That would be a good way to test whether my concerns are real. I’m tempted to recommend that the Fund should be boycotted in protest at the sums and strictures involved (there goes my invitation to the White House), but I know that’s unrealistic when resources are in such short supply. Nevertheless, civil society surely deserves much better than this.</description>
		<content:encoded><![CDATA[<p>Thanks for the invitation to comment on the Social Innovation Fund, though my first reaction is whether to laugh or cry – trillions of dollars with almost no strings attached to bail out Wall Street and $50 million for civil society surrounded by bureaucracy and micro-management by numbers? It’s not just the amounts that are derisory, but the fact that the mechanisms involved are so lacking in, well, innovation. These are the same ideas that we know don’t work if you really want social change -empowering distant intermediaries, increasing the number of hoops that groups must jump through, and investing scarce resources in number-crunching in lieu of real evaluation. The whole scheme is implicitly biased towards those who speak the language of the “new philanthropy” and the service-delivery efforts they support, but there’s no evidence that these approaches make the biggest impact on what matters most – the structural and systemic problems in society that hold so many people back. Wouldn’t more investment in tackling those problems be “social innovation?”</p>
<p>For example, the call for &#8220;rigorous evidence&#8221; excludes evidence that is rendered rigorous by means other than experimental design and randomized trials (p11 and p15), despite the documented weaknesses of these methods and the strengths of alternatives like action-research. Any activity which cannot be subjected to these methods will be excluded. That means most things are key to long-term social transformation.</p>
<p>Providing for only 5 per cent for administrative costs and insisting on an equal financial match will privilege cash-rich intermediaries who may not be the best-equipped in program terms (i.e. those with their ear closest to the ground, or those who are best at supporting smaller organizations with non-financial help). The usual suspects will win, and their biases will be replicated throughout the system. And one could go on.</p>
<p>Perhaps we should run a sweepstake on who will get resources from the Fund and publish the results? That would be a good way to test whether my concerns are real. I’m tempted to recommend that the Fund should be boycotted in protest at the sums and strictures involved (there goes my invitation to the White House), but I know that’s unrealistic when resources are in such short supply. Nevertheless, civil society surely deserves much better than this.</p>
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		<title>By: Adin Miller</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8441</link>
		<dc:creator>Adin Miller</dc:creator>
		<pubDate>Tue, 05 Jan 2010 21:04:56 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8441</guid>
		<description>By raising the minimum grant award level and the cash match requirement, the Corporation has dramatically narrowed the pool of community foundation that might apply to be a SIF intermediary. I ran a quick search on the Foundation Center database for community foundations with assets of $150M or greater (i.e., five times the size of Eileen&#039;s foundation and representative of the increase in the SIF match requirement) and came up with 69 foundations that would qualify with most of them based in urban centers. And that assumes that those foundation either have unrestricted resources available to them or can raise at least 50% of the match requirement within a short period of time.</description>
		<content:encoded><![CDATA[<p>By raising the minimum grant award level and the cash match requirement, the Corporation has dramatically narrowed the pool of community foundation that might apply to be a SIF intermediary. I ran a quick search on the Foundation Center database for community foundations with assets of $150M or greater (i.e., five times the size of Eileen&#8217;s foundation and representative of the increase in the SIF match requirement) and came up with 69 foundations that would qualify with most of them based in urban centers. And that assumes that those foundation either have unrestricted resources available to them or can raise at least 50% of the match requirement within a short period of time.</p>
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		<title>By: Sean Stannard-Stockton</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8440</link>
		<dc:creator>Sean Stannard-Stockton</dc:creator>
		<pubDate>Tue, 05 Jan 2010 20:36:27 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8440</guid>
		<description>Adin and Eileen,
Thanks for these. I&#039;ll be posting them both.</description>
		<content:encoded><![CDATA[<p>Adin and Eileen,<br />
Thanks for these. I&#8217;ll be posting them both.</p>
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		<title>By: Eileen Ellsworth</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8439</link>
		<dc:creator>Eileen Ellsworth</dc:creator>
		<pubDate>Tue, 05 Jan 2010 19:48:28 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8439</guid>
		<description>Sean:  Thank you for helping to bring good information and thougtful attention to the SIF grant process.   I run the Community Foundation for Northern Virginia.  Today on my foundation leadership blog - http://foundationleadership.blogspot.com - I have posted my comments to the draft NOFA.  If you&#039;d like to reprint them here or link to my blog for others to see, I would be very grateful.</description>
		<content:encoded><![CDATA[<p>Sean:  Thank you for helping to bring good information and thougtful attention to the SIF grant process.   I run the Community Foundation for Northern Virginia.  Today on my foundation leadership blog &#8211; <a href="http://foundationleadership.blogspot.com" rel="nofollow">http://foundationleadership.blogspot.com</a> &#8211; I have posted my comments to the draft NOFA.  If you&#8217;d like to reprint them here or link to my blog for others to see, I would be very grateful.</p>
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		<title>By: Adin Miller</title>
		<link>http://www.tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft/comment-page-1#comment-8437</link>
		<dc:creator>Adin Miller</dc:creator>
		<pubDate>Mon, 04 Jan 2010 18:21:00 +0000</pubDate>
		<guid isPermaLink="false">http://tacticalphilanthropy.com/2010/01/social-innovation-fund-process-draft#comment-8437</guid>
		<description>Sean, thanks again for hosting the discussion on the SIF. My principle questions that I&#039;ll submit to the Corporation are:

1.	Could the strong focus on “proven initiatives” automatically eliminate the truly innovative idea that has not received sufficient funding or had sufficient time to develop a history of proven impact?

2.	The draft NOFA requires both grantmakers and their grantees to match the grants on a one-to-one ratio. Can the grantmakers cover the match requirements for both the intermediary and local organizations or does the Corporation require a separate founding source for the latter?

3.	The draft NOFA places a strong emphasis on evidence. How will the Corporation evaluate foundations and their grantees’ efforts to achieve measurable outcomes?

4.	The definition of an intermediary remains vague: it could be a foundation or government agency but also a “high-engagement philanthropy organization” – what kind of organization is that?

5.	If a foundation is selected and needs to run a competition to select its grantees, must that selection and awarding process be complete by September 30, 2010?

6.	What’s involved in the Corporation’s due diligence review of a foundation? How much transparency will foundations be required to provide?

7.	The Corporation states that “final SIF award decisions also may be weighed based on the outcome of other large Federal grant competitions.” Is that limited to only other Corporation grant competitions or does that include grant competitions managed by other federal agencies?

8.	Who will carry the burden of the evaluation expenses? The intermediary grant recipient or the Corporation? Does the Corporation expect grantees to set aside a minimum percentage of funds to fund evaluation efforts? If not, might funders be expected to cover these expenses on their own? Can foundations use SIF funds to underwrite expenses related to Learning Communities or must that be covered by direct program expenses?

9.	Will the Corporation penalize foundations that have not had a historically transparent approach to identifying and selecting innovative projects to fund?

10.	The draft NOFA states that foundations will also need to ensure that their grantees are not receiving “large amounts of other Federal innovation funds.” How does the Corporation define both “larger” and what constitutes other Federal innovation funds?

I&#039;ve added more general observations on the SIF and its possible impact on foundation transparency and other issues here: http://www.adinmiller.com/content/could-social-innovation-fund-generate-more-foundation-transparency.</description>
		<content:encoded><![CDATA[<p>Sean, thanks again for hosting the discussion on the SIF. My principle questions that I&#8217;ll submit to the Corporation are:</p>
<p>1.	Could the strong focus on “proven initiatives” automatically eliminate the truly innovative idea that has not received sufficient funding or had sufficient time to develop a history of proven impact?</p>
<p>2.	The draft NOFA requires both grantmakers and their grantees to match the grants on a one-to-one ratio. Can the grantmakers cover the match requirements for both the intermediary and local organizations or does the Corporation require a separate founding source for the latter?</p>
<p>3.	The draft NOFA places a strong emphasis on evidence. How will the Corporation evaluate foundations and their grantees’ efforts to achieve measurable outcomes?</p>
<p>4.	The definition of an intermediary remains vague: it could be a foundation or government agency but also a “high-engagement philanthropy organization” – what kind of organization is that?</p>
<p>5.	If a foundation is selected and needs to run a competition to select its grantees, must that selection and awarding process be complete by September 30, 2010?</p>
<p>6.	What’s involved in the Corporation’s due diligence review of a foundation? How much transparency will foundations be required to provide?</p>
<p>7.	The Corporation states that “final SIF award decisions also may be weighed based on the outcome of other large Federal grant competitions.” Is that limited to only other Corporation grant competitions or does that include grant competitions managed by other federal agencies?</p>
<p>8.	Who will carry the burden of the evaluation expenses? The intermediary grant recipient or the Corporation? Does the Corporation expect grantees to set aside a minimum percentage of funds to fund evaluation efforts? If not, might funders be expected to cover these expenses on their own? Can foundations use SIF funds to underwrite expenses related to Learning Communities or must that be covered by direct program expenses?</p>
<p>9.	Will the Corporation penalize foundations that have not had a historically transparent approach to identifying and selecting innovative projects to fund?</p>
<p>10.	The draft NOFA states that foundations will also need to ensure that their grantees are not receiving “large amounts of other Federal innovation funds.” How does the Corporation define both “larger” and what constitutes other Federal innovation funds?</p>
<p>I&#8217;ve added more general observations on the SIF and its possible impact on foundation transparency and other issues here: <a href="http://www.adinmiller.com/content/could-social-innovation-fund-generate-more-foundation-transparency" rel="nofollow">http://www.adinmiller.com/content/could-social-innovation-fund-generate-more-foundation-transparency</a>.</p>
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