Federal grant applicants should pay close attention to the newly issued funding opportunities from the Substance Abuse and Mental Health Services Administration (SAMHSA). Several recently released Notices of Funding Opportunity (NOFOs) include a new restriction that limits the number of applications SAMHSA will accept and review.

In a NOFO posted on June 11, SAMHSA stated, “SAMHSA will accept and review only the first 30 complete, successfully submitted, and high-quality applications received via eRA. Once this threshold is met, the submission portal will close, and no further applications will be considered.” While 30 applications may seem like a high number, the particular NOFO states SAMHSA will make eight grant awards—which translates into roughly four applications per award, a relatively small competitive set. 

Feldesman has identified at least five additional SAMHSA NOFOs containing similar limitations.  Depending on the funding opportunity, SAMHSA has stated that it will only review the first 50, 60, or 70 applications submitted.  For example, the “Building Communities of Recovery” NOFO, posted on June 16, states that SAMHSA intends to award 27 grants but will accept and review “only the first 70 complete, successfully submitted, and high-quality applications received via eRA .”  This translates into approximately 2.5 applications per award, an even smaller number than the example provided above.

Generally, award applications are open for 30 days before agencies review all submissions. The typical application period allows for a larger pool of organizations to submit merit-based applications with comprehensive scopes of project and budgets—as well as complete disclosures. 

SAMHSA’s limits on the number of applications reviewed could incentivize organizations to submit proposals prematurely, introducing a range of compliance concerns. It also remains unclear how SAMHSA defines a “high-quality” application or the basis for the numerical cutoffs in each NOFO. 

At this time, it is unclear whether other federal funding agencies will adopt similar practices. Notably, while several recently issued SAMHSA NOFOs contain caps on the number of applications that will be reviewed, other SAMHSA opportunities released during the same time period did not include similar restrictions.  

Applicants should carefully review each NOFO on its own terms and avoid assuming that all SAMHSA funding opportunities will be subject to application caps. Until there is greater clarity regarding SAMHSA’s approach, organizations should pay close attention to application requirements and timelines and consider beginning the application process as early as possible when these restrictions apply.

Feldesman’s federal grants attorneys are monitoring developments related to SAMHSA’s application review limits and other recent changes affecting federal funding opportunities. If you have questions about how these developments may affect your organization, please contact Mindy Pava or Ted Waters.