Miscommunication and confusion leads to lost opportunities for COD students
by Debbie Fried
As jovial well wishers filled goblets full of Hershey’s kisses for outgoing President Jerry Patton last week, joviality was not the universal feeling permeating the halls of COD. When it comes to losing an opportunity to vie for a grant aimed to further the enrichment of Math, Engineering, and Science Achievement (MESA) students at COD, anything but kisses will be exchanged between some members of faculty and administrators.
Consternation and betrayal are words that could explain what had appeared as a breach in “standard operating procedures” for community colleges throughout the country: Maintaining grant eligibility. This especially hits home when your school is a federally Designated Hispanic Serving Institution, able to garner millions of additional dollars in funding for student learning and development.
College of the Desert has held the official designation of a Hispanic Serving Institution (HSI) for the past several years, along with schools in many other border states, having earned that status by meeting or exceeding a Hispanic student population of at least 25 percent. As such, COD is entitled to apply for and enter nationwide competitions for grants that cater to the needs of students who are often low-income and in need of support services to help them wade through the often murky waters on the road to higher education. Hence, COD has an entire division of Student Support Services, led by Dean of Student Support Programs and Services, Adrian Gonzales.
An explanation of currently awarded Title V funding is found on the college’s webpage:
“In October 2010, College of the Desert received a $3.25 M grant from the U.S. Department of Education to focus on student success and development, with special emphasis on Hispanic, low income, and first generation college students.”
Recently, news had been surfacing that COD had “lost its HSI designation,” a charge which Gonzales emphatically denies. Beyond this, a clash in interpretation of the Code of Federal Regulations (CFR) seems to lie at the crux of the problem that drew grant preparations in the MESA Department to a screeching halt.
Initially, it was assumed that COD administration had completed the short, two page form required by the Department of Education (DOE) to maintain eligibility that would allow COD to vie for a Title V Developing Hispanic-Serving Institutions cooperative grant for fiscal year 2012.
On October 30, 2011, COD sent a group of Authorized Organizational Representatives (AOR’s) and Title V specialists to San Antonio, Texas, to attend a U.S. Department of Education HACU training conference (Hispanic Association of Colleges and Universities) on the “how to’s” of obtaining funding opportunities for HSI institutions.
“AOR” is federal government jargon for those who have received authorization by their institutions who are recognized as trained and qualified parties to “hit the submit button” in response to federal grant award postings. Sharon Benson, secretary in the Office of Student Affairs, for example, is a designated AOR.
Advisement was clearly posted as part of a presentation given at the San Antonio HACU conference last year. A PowerPoint presentation stated: “Basic eligibility application for Fiscal Year (FY) 2012 is estimated to be published in December of 2011.” Fiscal years run from Oct. 1 of one year through Sept. 30 of the next.
Each year brings new opportunities for COD to present itself as a contender for competition. This competition does not come easy and requires diligent research in crafting a persuasive proposal, and attention to detail in following regulation and strict protocol that would cause many of little patience and fortitude to bristle.
During the HACU conference, basic procedures and mandatory Title V Program eligibility standards were explained. In large font, placed in the context of a PowerPoint presentation was emblazoned the phrase:
“Your institution must be certified as an eligible institution before your proposal will be reviewed and before you can receive federal grant funds. You must apply every year you seek new funds.” (Underlining provided by HACU)
As a campus specialist, COD Executive Director of Title V and Institutional Advancement, Pam Hunter, was consulted on the matter. Hunter states she did not attend the HACU conference last October, and “does not have a lot of knowledge” regarding HSI [designation] but she does acknowledge “some confusion” surrounding the issue.
Hunter did confirm that COD has maintained the HSI designation “for a number of years,” adding that as it is a five-year designation, COD would be in its second cycle of holding this door-opening, grant-funding distinction.
As announced, and anticipated by MESA Director Dr. Carl Farmer, the ed.gov website, a go-to site for the posting of federal grant competitions had posted the Title V Developing Hispanic Serving Institutions cooperative grant for FY 2012, with a response date of February 10.
Dr. Farmer had directly contacted the DOE, speaking to representative, Carnesia Proctor, in mid-February. Proctor assumed that COD had applied for and received eligibility by the February 10 deadline as he was posing questions regarding further protocol, and so advised Dr. Farmer “you may now apply for another grant.”
The STEM (Science, Technology, Engineering and Mathematics) grant had been underway to benefit the future East Valley Campus of COD, with the aim of funding well over one hundred thousand dollars in lab equipment, as well as providing extended learning opportunities for students to participate in cooperative summer learning programs at Cal State and UCR.
This grant was to provide real life field-related experience that would have been a boon to students on their college applications, says Sandra Farmer, a member of the Board of Trustees overseeing the Title V STEM and Articulation Grant project as a researcher and coordinator.
Mrs. Farmer explains the intentions of the MESA grant proposal team:
- To apply for a cooperative “Developing Hispanic Serving Institution Grant at $775,000 per year
- An individual HSI STEM Grant at $870,000 per year
- A cooperative HSI STEM Grant at $1.2 M/per year
If given the chance to enter the competition, each grant would be awarded for a five-year period, says Mrs. Farmer, a grant writer for 35 years. As an HSI, COD has earned the designation allowing the school “to apply for all.”
Mrs. Farmer asserts she is well-versed in the procedural processes involved, including timely filing of appropriate forms and building collaborative teams – as well as consulting legal advisors and external evaluators, such as Ed Morante, in advance. Morante “is a former emeritus faculty member” who reportedly was paid $5,000 for his services as a grant writer and consultant in 2011.
Dr. Farmer had been in contact about the intent to apply for a cooperative HSI STEM grant with Student Services Dean, Gonzales, he replied “the deadline may have passed” and referred him to the ed.gov website for further clarification.
On Tuesday, February 28, DOE representative Proctor soon confirmed Dr. Farmer’s fear: “If your institution did not apply for designation by the February 10, 2012, deadline, your institution is not eligible.”
This did not imply that COD was no longer considered an HSI but rather that it was no longer eligible to apply for a grant during 2012. Sandra Farmer states emphatically that they had been watching for the posting since having missed the deadline last year. Both Dr. Farmer and Mrs. Farmer had been confident that the short, 2-page eligibility form had been submitted, allowing the grant process to move forward.
Mrs. Farmer likens the automatic annual eligibility renewal akin to applying for a Driver’s License: “You may not drive, but at least you have the license to drive if you want to. You can wave the HSI flag all you want, claiming to be a Hispanic Serving Institution, but without applying for the grants, it means nothing.”
According to Mrs. Farmer, a grant writer affiliated with Mt. San Antonio College informed her “this institution maintains eligibility on a yearly basis- no questions.” Kathleen, an Electronic Proposal Coordinator at CSUSB, was asked, “Is the eligibility form ‘automatically’ submitted? To which she responded, “Once certified [as eligible] we expect to wait for next year’s renewal. We stay on top of it.”
Once it became clear that the February 10 eligibility deadline had come and gone, the search was on by the director of MESA to learn what may have led to this state of affairs. Communications ensued to the office that had historically maintained HSI eligibility: Adrian Gonzales, Interim Vice President of Student Affairs.
During in depth discussions regarding the matter, Gonzales painstakingly explained his rationale for not responding when he saw the competition posting on the ed.gov website: “When [the posting] came in December, we already had an individual grant and two federal grants.”
“I made the decision that we were not going to pursue another Title V grant, but someone else could have.” Title V specialist Hunter also confirmed filings for eligibility was typically done through the Student Affairs office. However, for fiscal year 2012, Hunter echoes the sentiment of Gonzales, stating, “We did not intend to apply for a grant, therefore, we decided not to file for eligibility.”
Gonzales explained, “Somebody would’ve had to say, ‘we’re interested.’” He explained that Dr. Farmer would have done well to first consult with the dean of liberal arts and sciences or the vice president of academic affairs. He then presented the COD Grant Proposal Concept Form, which both he and Hunter state is one of the primary steps in the multi-step procedural chain.
“There is no particular party responsible for responding to grant solicitations on the government website at COD; we are already immersed in two Title V TRIO grants.” Further, “since there is no “grants office” [per se, at COD] there is a greater pressure left to disburse funds,” says Gonzales.
When COD enters into a cooperative grant, one of the first matters of business is for teams from each institution to commence the fast and furious work to make sure an interest is established and a team of collaborators are in place to follow through with the project. As Mrs. Farmer explains it, “you can’t do a grant in 30 days; you have to have your contacts in place [beforehand].”
Says Mrs. Farmer, “I thought COD deserved the best, and therefore [I] had contacted another very qualified grant writer who was very experienced in HSI grants. He had referred us to an outside evaluator to work with him on the grant.”
In addition to not desiring to apply for any further grants in the current fiscal year, Gonzales also explained that COD’s eligibility also may not have been granted on grounds that not more than one cooperative grant could be in place at the same time as the grants that have already been awarded. He also stated he believed that COD could not apply as the lead partner with Cal State.
Upon receiving this news, Dr. Farmer again states to Proctor that he wants to be clear on the eligibility requirements, specifically if COD could apply as the lead institution (in cooperative grants with other schools, one school is designated as the “lead” and the other is “secondary”).
Proctor responded, “You can apply as the lead and/or as the partner. If you are applying as the lead, the partnering institution must be an institution of higher education.” Explicitly stated on the form’s cover page was the caveat, “Important: You are required to provide the information requested [to gain eligibility] in order to retain a benefit” (i.e. submittal of the required 2-page eligibility form). This instruction was given under the assumption by the DOE that current eligibility had already been established.
When Hunter was asked if she was aware of a MESA’s cooperative STEM grant hitting a snag in the application process, she replied, “I was not in the loop regarding any eligibility for grants [this year], it was only after the deadline had passed that I heard someone was working on the application.”
It appears that Gonzales and the Farmers are consulting the same passages of the Code of Federal Regulations, quoting the same sections of Title 34, part 606, as a basis for their conclusions. Based upon her conclusions, Mrs. Farmer asks, “Is [Gonzales] really stating that the interpretation of the same regulations in CFR 34, part 606 changed from 2011 to 2012?”
Hunter was also asked if she had any knowledge of a change, and replied that she was not aware of any. Farmer continues, “If we accept Gonzales’ interpretation, would we not have been eligible for any additional funding from the DOE in 2011, as well? Then why did COD pay Morante $5,000 to write an individual HSI STEM grant proposal that he maintains we would have been ineligible for?” (COD had applied for a STEM grant for 2011 which was not awarded).
A U.S. Department of Education’s letter dated March 8, 2011, addressed to Diane Ramirez (whom Gonzales replaced upon her retirement in July 2011) opens with the following proclamation:
“We are pleased to inform you that your recent request for Designation as an Eligible Institution under Title III and Title V programs….is approved…you do not need to reapply for designation as an eligible institution for five years-UNLESS you wish to apply for a grant under the Title III or Title V, Hispanic Serving Institutions Programs. You must apply for eligibility designation in each year you wish to participate in a program competition for funding.”
“We were eligible in 2011 and 2012”, maintains Mrs. Farmer. “However, in 2012 we are no longer eligible because COD … intentionally did not file the institution’s eligibility form by February 10, 2012. Again, I ask, why?”
When questioned on the matter of the failure of MESA grants coming to fruition, both Hunter and Gonzales explained that with the currently active TRiO grant funding, plans are underway to help accomplish some of the Title V objectives for student services – and also help prevent the kind of confusion and frustration demonstrated by the MESA STEM Grant mishap of 2012.
“The grants oversight responsibility is mine,” said Hunter. Since it is not “in the foreseeable future for COD to open a ‘grants office,’ she does offer some consolation and encouraging news: “We are working on a ‘grants portal’ to create a more effective grant application process, as well as grants monitoring.”
A portal on the website would provide a centralized place for all parties in every step of the chain to locate all pertinent information about grant competition and those in process, advising of status, deadlines, costs, student and institutional demographics- “all information will be found easily on the portal,” states Hunter. Even the annual award [of eligibility] would be found on the portal.”
When referring to the grant monitoring and application process, says Hunter, “we have to ask, ‘Is this a good opportunity for College of the Desert, or just a good opportunity?’ I don’t pretend it’s a flawless system.”