In cluster randomized trials (CRTs), the study units usually are not a simple random sample from some clearly defined target population. Instead, the target population tends to be hypothetical or ill-defined, and the selection of study units tends to be systematic, driven by logistical and practical considerations. As a result, the population average treatment effect (PATE) may be neither well defined nor easily interpretable. In contrast, the sample average treatment effect (SATE) is the mean difference in the counterfactual outcomes for the study units. The sample parameter is easily interpretable and arguably the most relevant when the study units are not sampled from some specific super-population of interest. Furthermore, in most settings the sample parameter will be estimated more efficiently than the population parameter.