In mid December, the Corporation for National & Community Service released a Draft Notice of Funds Available (NOFA) for the Social Innovation Fund. They are now accepting public comment on the document until January 15 (simply email your comments to SIFinput@cns.gov). Because the Corporation will not be responding to individual comments nor making them public, I’ve offered to publish comments here. Simply email me your comment and I’ll run it as a post. My hope is simply to stimulate discussion around how the Fund should operate.
I’ll likely submit my own comment. But today I just want to highlight some elements of the draft NOFA. For background, please reference my previous posts explaining the Social Innovation Fund and why it matters.
The Corporation is specifically looking for comments in three areas 1) The process they are using to identify “philanthropically underserved communities”, 2) How the intermediaries should asses the impact of their work and how the Corporation should hold the intermediaries accountable for their performance, 3) What framework should be used to manage appropriate accountability from both subgrantees and intermediaries.
To be awarded funding, intermediaries will need to demonstrate 1) The ability to identify innovative solutions and invest in growth, 2) A track record of using rigorous evidence, 3) Expertise and demonstrated impact in their area of focus, 4) A depth and breadth of relationships with stakeholders in their focus area.
While evidence-based decision making is a core element of the Fund, the NOFA states “The corporation recognizes that in many fields and in many parts of the country, such evidence is not available. In those cases, the Corporation is committed to funding promising efforts in order to build the base of evidence about what works, improve programs, and inform future investments.”
The Fund will be funding intermediaries (grantmakers) who will then be funding “subgrantees”. However, in evaluating two applications of equal merit, the Corporation may give preference to the applicant that identifies its subgrantees in its application.
The Fund expects to select five to seven intermediaries.
The NOFA states, “the Corporation expects to have substantial involvement with the intermediary organizations as they carry out approved activities. In particular, the Corporation anticipates involvement in 1) reviewing subgrantee outcomes and program compliance, 2) the development of a plan for evaluating subgrantees including the specific questions the evaluation intends to answer, the type of research design, the timeline and budget, and who will conduct the evaluation, 3) The development of a final, detailed plan for expansion or replication of subgrantees, 4) The development of “best practices deliverables”, 5) Other appropriate activities as specified in the final award.
Intermediaries may not use more than 5% of the grant for their own administrative costs and may not use more than 15% of the grant for direct program costs (ie. at least 80% of the Fund grant must flow to subgrantees).
Intermediaries will need to demonstrate in their applications how they use evidence in their grantmaking process. While the Fund recognizes the variable levels of evidence in difference fields, the NOFA states “The best evidence will come from independent, well-designed studies using experimental and quasi-experimental designs.”
Intermediaries will be required to participate in “learning communities” for the Fund. These learning communities will interact regularly to collaborate with each other on grantee projects.
The Corporation will be engaging outside reviewers with expertise in innovation, evaluation and replication to help them evaluate applications.
Applications must describe how their grantmaking process will ensure that subgrantees 1) have proven/promising evidence and a track record of achieving specific outcomes, 2) have articulated measurable outcomes, 3) has a well-defined plan for replicating, expanding or supporting their initiative, 4) has strong leadership and financial and management systems, 5) will meet the requirements for matching funds and 6) is committed to the use of data collection and evaluation.
The application deadline for intermediaries has yet to be announced, but the Corporation expects to announce the intermediaries they will be funding in the summer of this year.
Materials generated with Corporation funding will be made available to the public.
I’ve read the full NOFA and the Act authorizing the Fund. I’m happy to try to answer questions that anyone might have.
Sean, thanks again for hosting the discussion on the SIF. My principle questions that I’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’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.
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’d like to reprint them here or link to my blog for others to see, I would be very grateful.
Adin and Eileen,
Thanks for these. I’ll be posting them both.
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’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.
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 “rigorous evidence” 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.
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’s i3 program — emphasize “strong impact” 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’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.