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Second Annual National Endowment for the Humanities Plain Writing Compliance Report

As was the case last year, in 2012-2013 we have continued to focus our efforts on the writing and editing of application guidelines: the instructions for applicants to our grant programs. We currently administer approximately thirty-five grant programs, a list of which can be found here.

Joel Schwartz (NEH’s Chief Guidelines Officer, the official principally responsible for writing and editing these documents) is overseeing the agency’s Plain Writing initiative. One of his responsibilities is to ensure that the application guidelines are as comprehensible as possible.

This year we have also begun what will be a multiyear effort to simplify the language in NEH’s grant management documents: that is, the documents that tell grantees what they need to do to comply with the conditions of their awards. To date we have published revised versions of nine of these documents, focusing on those that are most commonly used. Six of these documents pertain to institutional grantees: The General Terms and Conditions for Awards (GTCA), the Addendum to the GTCA, Performance Reporting Requirements, Financial Reporting Requirements, the Federal Matching Funds Guidelines, and the Administration of NEH Challenge Grants. The other three documents pertain to individual grantees: General Information on NEH Fellowships, General Information on Summer Stipend Awards, and General Information on Awards for Faculty.

To give you a sense of the sorts of changes that we are making in grant management documents, here are two examples: the first is taken from the GTCA, and the second is taken from the Administration of NEH Challenge Grants. Below you’ll find the “before” and “after” versions of each extract.

The GTCA example appears in the glossary of terms with which the document begins.

Before: “Simplified Acquisition Threshold: This term replaces ‘small purchase threshold,’ and the threshold is currently set at $100,000 [41 U.S.C. 403 (11)].”

After: “Simplified Acquisition Threshold: This term replaces ‘small purchase threshold,’ and is currently set at $150,000 [41 U.S.C. 403 (11)]. It refers to the dollar amount ceiling under which federal agencies are permitted to use simplified procedures for purchasing goods or services.”

We think that the “after” version is more helpful to readers: it explains what the threshold is, and how it is used—instead of simply listing a dollar amount.

The second example, taken from the Administration of NEH Challenge Grants, concerns construction and renovation projects that affect historic properties. The National Historic Preservation Act (NHPA) applies to such structures.

Before: “Section 106 [of the NHPA] requires NEH to review the effects of projects offered NEH funding on historic properties (i.e., National Register of Historic Places (National Register) -listed or -eligible properties), and when applicable, provide the Advisory Council on Historic Preservation (ACHP) an opportunity to comment on such projects prior to the expenditure of any Federal funds.”

After:Prior to the expenditure of any federal funds, Section 106 [of the NHPA] requires NEH to review the effects of projects offered NEH funding on historic properties that are listed or eligible for listing in the National Register of Historic Places. When applicable, NEH must also provide the Advisory Council on Historic Preservation (ACHP) an opportunity to comment on such projects prior to the expenditure of any federal funds.”

We think the “after” version is considerably clearer. We split the single lengthy sentence in the “before” version into two more manageable sentences. We also eliminated the confusing proliferation of parentheses within parentheses. Finally, we replaced the awkward construction involving hyphens (“National Register-listed or -eligible properties”) with a much simpler construction: “historic properties that are listed or eligible for listing in the National Register of Historic Places.”

The language in many NEH documents—this is true of instructions for applicants as well as instructions for grantees—is often unavoidably technical. (In particular, the legal language found in many grant management documents is necessarily precise and therefore unchangeable.) Working within that very real constraint, we will continue to strive to make our documents as readable and as comprehensible as can be.

Joel Schwartz, NEH’s Chief Guidelines Officer, prepared this report.