14 Action Steps: CLAS standards are a foundation in proposals
14 Action Steps: CLAS standards are a foundation in proposals

Grant application instructions don’t always request information on how your organization will ensure its services will equally benefit diverse members of the community. But even if funders don’t ask that question, grant proposals that infuse diversity and equity approaches throughout the narrative are stronger because they demonstrate understanding of the expansive demographics of the service area and a commitment to mutual progress. 

“When developing proposal narratives, the National Standards for Culturally and Linguistically Appropriate Services (CLAS) can be extremely helpful. Because CLAS standards are intended to promote equity, improve service quality, and eliminate care disparities they provide solid guidance for integrating diversity, equity, and inclusion principles into your program plan.

The U.S. Department of Health and Human Services Office of Minority Health (OMH) in 2000 established CLAS. In response to a deeper understanding of cultural and linguistic competency and the increasing diversity of the U.S. population, in 2013 the OMH published enhanced CLAS standards. While they were developed specifically for healthcare services, health includes physical, mental, social, and spiritual wellbeing so CLAS standards are relevant to any service your nonprofit might provide. 

CLAS Standards include 14 action steps intended to promote services that respect the whole individual and respond to each individual’s specific needs. The Principal Standard is to provide effective, equitable, understandable, and respectful quality care and services that are responsive to diverse cultural health beliefs and practices, preferred languages, health literacy, and other communication needs. OMH sorts action steps to achieve the Principal Standard into three categories. Here’s a quick synopsis of the requirements within each category. 

* Governance, Leadership, Workforce: (1) Promote CLAS through policies, practices, and resource allocation; (2) Build a culturally and linguistically diverse leadership team and workforce representative of the population served; and, (3) Provide ongoing training in culturally and linguistically appropriate policies and practices. 

In grant proposals, when describing your organization, you might explain how it has assessed its policies and adjusted programming and budgeting to ensure equity in service provision. You might describe how your board and staff reflect the diversity of the community, and how leadership, staff, and volunteers receive regular training to support best practices in culturally and linguistically appropriate approaches.

* Communication and Language Assistance: (4) Offer no-cost language assistance to those with limited English proficiency or other communication needs; (5) Inform people (verbally and in writing) of the availability of no-cost language assistance; (6) Ensure those providing language assistance are competent; and, (7) Provide easy-to-understand print and multimedia materials and signage in languages commonly used by those in the service area.

In grant proposals, be sure to address how you’ll ensure equal service to those who speak languages other than English, including sign language. Budgets that support translation services, linguistically diverse signage, and interpretation of materials into the most common languages in your community provide a concrete example of how your organization allocates resources to support CLAS standards. 

* Engagement, Continuous Improvement, and Accountability: (8) Set culturally and linguistically appropriate goals, policies and accountability procedures and infuse them throughout the organization; (9) Continually assess CLAS-related activities and integrate CLAS measures into evaluation and continuous quality improvement work; (10) Maintain accurate demographic data to evaluate the impact of CLAS on outcomes; (11) Conduct regular community assessments and use the results to plan services that are responsive to the cultural and linguistic diversity of the population; (12) Engage the community in designing, implementing, and evaluating policies and services; (13) Be sure grievance processes are culturally and linguistically appropriate; and, (14) Inform all stakeholders of your organization’s progress in implementing CLAS.

In grant proposals, it’s important to describe how your organization holds itself accountable through established evaluation and continuous quality improvement (CQI) processes that use disaggregated data to identify where adjustments are needed to ensure equal benefit to culturally and linguistically diverse groups. For example, even though the overall achievement of children in your tutoring program may be stellar, disaggregated data may show that children who are English language learners are disproportionately represented in those who are not succeeding.

Basing grant requests on community assessments and engaging those with lived experience of an issue in program planning and evaluation are best practices. Engaging them as staff members or volunteers in program implementation further ensures their voices inform your work. There’s a lot to unpack within this CLAS category and you might find focusing on the mantra “nothing about me without me” to be helpful. 

You can access the CLAS standards and a wealth of information on implementation at the HHS Office of Minority Health (OMH) website (https://bit.ly/3S9ebSq) and there are several practical guides to help you implement the standards within your organization and programs. HHS provides a National CLAS Standards Implementation Checklist (https://bit.ly/3rhCrGd), and the Centers for Medicare & Medicaid Services and the OMH published A Practical Guide to Implementing the National CLAS Standards: For Racial, Ethnic and Linguistic Minorities, People with Disabilities and Sexual and Gender Minorities (https://go.cms.gov/3qZYWPE).

Bonus Idea

Confusing questions in funding application guidelines can test even the most seasoned grants professional. But experience, grit, and a call to the funder (if possible) will generally get you over the bump. 

But if you neglect day-in-day-out statistical housekeeping, even clear, straight-forward questions can whip up a whirlwind of unexpected distress and dull your competitive edge. It is astonishing the number of nonprofit managers who cannot provide detailed, accurate information on the number of people they serve each year, the demographics of their beneficiaries, and the types and amounts of service provided.

Funders want to understand your constituency and reach, and if you can’t answer the basic questions, you’ll have a hard time convincing them you can manage a grant.

Producing solid service data is a requirement for good organizational management and board members and administrators should be as demanding as funders. Without basic data, how can you prioritize use of resources, determine which groups need additional attention, and understand exactly who you are reaching? If you can’t explain how many people you assist in what ways, why should the community continue to contribute to your annual fund drive?

Every nonprofit manager can find a management information system (MIS) that fits organizational needs and budget. Lack of a decent MIS is rarely the underlying problem — its lack of attention and commitment. Deciding what data to collect, when, and in what way takes serious, focused thought. If your data collection is haphazard, lacks consistency across programs, and is not regularly assessed, you’re asking for trouble. 

If you only pull up the data when the funder requires it, you’re likely to find yourself swamped with conflicting numbers, incomplete counts, and gaping holes in logic. The numbers might not make sense.

Do an annual review, even if you are gathering service data consistently. Pull together a work group and assess what you’re collecting, how it is meeting organizational needs, where there are gaps or inconsistencies to fix, whether input is accurate, and whether the reports produced are dependable and logical. As programs evolve and funders change, you’ll often find your data gathering is lagging behind.

If you aren’t using a quality MIS, pull together a work group to decide what information you will gather when, how you’ll track accuracy, how you’ll evaluate the quality of the information, and how you’ll identify needed changes. Then research available MIS options that are a fit with your needs and pocketbook. 


Barbara Floersch, grants expert and author of “You Have a Hammer: Building Grant Proposals for Social Change.” Her email is barbara@barbarafloersch.com

©Copyright 2022, Barbara Floersch