The attention lavished on the Social Innovation Fund (SIF) this week has been far from positive. Building on posts by the Nonprofit Quarterly and Paul Light, Stephanie Strom’s New York Times article in today’s edition cites possible conflicts of interest by SIF Director Paul Carttar and Corporation for National and Community Service CEO Patrick Corvington and calls into question whether these pre-existing relationships affected the selection process.
In actuality, I believe that these possible conflict of interest issues are matters of perception instead of reality. As noted by Marta Urquilla, a senior adviser for the SIF, in the New York Times article, these conflicts of interests were anticipated and addressed in advance. For example, Steve Goldberg well-researched letter to the Nonprofit Quarterly, meticulously documents how the Corporation made sure to avoid any conflicts of interest. I can understand why people are fixated on these conflict of interest possibilities, but I think that’s somewhat misguided and potentially harmful.
Instead, there are two core issues we should focus on: a more proactive communication effort by the Corporation and the need for transparency on the review and selection process of the SIF intermediaries. If left unaddressed, the Corporation will continue to foster misguided attention on phantom conflicts of interest that will only fuel public misperceptions of the SIF and endanger its viability before the program even has a chance to truly generate impact.
So, moving forward, how does the Corporation rectify this situation? To quote Sean Stannard-Stockton in his post today, “let us seek the truth about what has happened.”
First, the agency needs to get ahead of the communication cycle: it’s in a reactive communication mode and losing the public perception battle. For example, the Corporation cannot just state that it will release the finalists’ proposals at some undefined date – it needs to establish dates by which the information will be provided and then meet those deadlines.
Second, it needs to provide more information about its processes. The transparency the Corporation’s processes required of SIF applicants (see pages 26 – 28 and 35 – 36 in New Profit’s proposal for example) needs to be applied to the agency’s processes as well. Steve Goldberg’s letter highlighted the waiver letter issued by the Corporation to Paul Carttar. It’s a complete gem of a document and it provides additional information about the review and selection processes. Combined with the Corporation’s public response on its review and application processes, we get a true sense of the processes. Taken together, the sequence involved:
- Staff review of applications for compliance with submission requirements.
- An initial peer review of eligible applicants involving three reviewers and one Corporation staff person as a facilitator. Each proposal was reviewed by two panels.
- A consensus meeting involving senior Corporation staff to review the top applications and “evaluate them in light of the goals of the SIF”. This meeting reduced the number of applicants to 31 possible intermediaries (i.e., SIF grant recipients).
- Expert review stage involving two expert reviewers with special attention on evaluation plans and replication potential.
- A second consensus meeting, “at which information from both the blended and expert reviews will be assessed.” This meeting reduced the number of applicants to 16 possible intermediaries.
- A pre-decision meeting with “the senior Corporation official designated by the CEO (hereinafter “designated official” or “designated selection official”) to make the selections.”
- A third review involving three external experts and Corporation senior staff. At the conclusion of the meeting, the Corporation staff narrowed the applicants to 11 possible intermediaries.
- Clarifying discussions by Corporation staff with the applicants.
- Final decision meeting at which the designated official made the final award decisions.
However, some questions about the blended review and selection process still remain:
- Did any of the two initial peer review processes involve Corporation staff in the scoring and ranking of proposals?
- Who were the senior Corporation staff involved in the first and second consensus meeting?
- What were the evaluation criteria for reviewing the applicants at the first consensus meeting?
- Did the expert review stages involve any evaluation criteria that were not published or know to the applicants?
- How was the designated official appointed to make the final award selections?
- What criteria were used to make the final award decisions?
The two documents related to the review and selection processes do not correlate exactly; it would be important to understand where this process deviated, if at all, from the above sequence.
I’ve compared the different transparency approaches used by the SIF and U.S. Department of Education’s the Investing in Innovation (i3) program. In clarifying its review and selection process, the i3 program has also provided more transparency. Its Notice of Funds Available specifically indicates that award decisions would made by integrating on “a rank order of applications based solely on the evaluation of their quality [by peer reviewers] according to the selection criteria” and “other information including an applicant’s performance and use of funds and compliance history under a previous award under any Department program.” The Department of Education also provides a very thorough stand-alone document that explicitly explains the i3 review and selection process. Unfortunately, the Corporation lacks such a succinct document.
The SIF, in contrast, lacks this level of transparency and clarity. Information on the selection and review processes was presented in its Notice of Funds Available (PDF; starting on page 18), but much remained ambiguous. The Corporation needs to provide a detailed overview of the review and selection processes. That should include details on how the agency selected and assigned its peer reviewers, how it assigned proposals to the review panels, how it conducted its peer reviews, how it conducted the follow-up clarifications with applicants, how it conducted its applicant eligibility and due diligence reviews, and how it integrated all these elements into the final ranking of proposals. Eventually, it should also release the names of its reviewers.
Given the negative attention now plaguing the SIF, the Corporation must step up and provide greater transparency and clarity on the review and selection processes. Let’s get at the truth so we can all focus on making the SIF successful and transformative.
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