October 20, 2016
A guaranteed way to add confusion, reduce objectivity, and create denied applications is to have broad, generalized categories or use catch-alls like “other catastrophic or extreme circumstances” or “other – please describe below.” Every careful analysis of a program invariably shows that the majority of denials are due to these subjective categories.
Overbroad categories also cause significant portions of applicant and reviewer frustration and confusion. Not only are these subjective categories an administrative headache, but they are also contrary to Best Practices and the regulatory requirement that the program be objective. In fact, the IRS stresses objectivity two ways – the charity must document its “objective criteria for disbursing assistance under each program” and “recipients of grants are selected based upon an objective determination of need.” See IRS Publication 3833.
Another reason for clarity and objectivity is so that even the reviewers are clear about what fits the fund criteria and what does not. Eight trained reviewers all sitting by themselves, looking at the same information, should all come to the same conclusion. This not only facilitates the program administration, but also creates a sense of fairness in the grant decision process amongst the employees. For example, one category which applicants and reviewers never get wrong is “death in the family,” which also provides a specific list of which family members are included. Something so easy to understand means an easier application, and a higher chance of approval.
The most often heard concern about clear and objective grant requirements is that someone with a hardship may end up falling outside of the criteria, and so there is a desire to cast a wider net. The reality is that whenever a program focuses its criteria and improves the objectivity it results in a more vibrant program which impact more people than before and improves the perception of the program. While at the same time this increases a programs compliance with the regulatory requirements of objectivity.