Purpose: The objective of the NSGP is to provide funding for physical and cyber security enhancements and other security-related activities to nonprofit organizations that are at high risk of a terrorist or extremist attack.

Terrorism: Any activity involving a criminally unlawful act that is dangerous to human life or potentially destructive of critical infrastructure or key resources, and that appears intended to intimidate or coerce a civilian population, to influence government policy by intimidation or coercion, or to affect the conduct of a government by mass destruction, assassination, or kidnapping.

• The State Administrative Agency (SAA) is the only eligible applicant to apply for funding to FEMA.
• Nonprofit organizations are eligible as subapplicants to the SAA. As such, nonprofit organizations must apply for NSGP funding through their SAA, who then submits all application information to FEMA.
• Nonprofit organizations may not apply directly to DHS/FEMA for NSGP funds.

Eligible organizations are:

• Registered 501(c)(3) nonprofit or otherwise are organizations described under section 501(c)(3) of the IRS Code of 1986 (IRC) and exempt from tax under section 501(a) of such code
• Have an active/valid filing with the IRS or the Texas Secretary of State to ensure 501(c)(3) status
• Have an active System for Award Management (SAM) registration*
• Able to demonstrate, through the application, that the organization is at high risk of a terrorist attack
• Faith based organizations may be exempted from providing proof of 501(c)(3) status (see next slide)

Every organization exempt from federal income tax under Internal Revenue Code section 501(a) must file an annual information return except:

• A church, an interchurch organization of local units of a church, a convention or association of churches
• An integrated auxiliary of a church
• A church-affiliated organization that is exclusively engaged in managing funds or maintaining retirement programs
• A school below college level affiliated with a church or operated by a religious order
• Church-affiliated mission societies if more than half of their activities are conducted in, or are directed at persons in, foreign countries
• An exclusively religious activity of any religious order

While FEMA requires only the UEI, Texas law requires all entities awarded funds through the SAA to maintain a full SAM registration throughout the period of the active grant.

SAM.gov is a federal system. The SAA is unable to assist with or resolve any complications with your organization’s SAM registration or UEI. Please visit the SAM.gov website for assistance.

SAM registrations do not have any associated costs. Any communication requesting payment for registration completion are likely fraudulent.

What type of entities/organizations are eligible to apply under NSGP?

The list below is not exhaustive and only provides examples of potential eligible organizations, all of which must be nonprofits.

What type of entities/organizations are not eligible to apply under NSGP?

NSGP-UA. Eligible nonprofit subapplicants located within UASI-designated high-risk urban areas may apply to the SAA to receive funding only under NSGP-UA.

Current designated UASIs

• Dallas/Fort Worth/ Arlington (Includes counties: Dallas, Denton, Tarrant and Collin)
• Houston (Includes counties: Harris, Fort Bend, Montgomery, Brazoria, and Galveston)
• San Antonio (Includes counties: Atascosa, Bandera, Bexar, Comal, Frio, Gillespie, Guadalupe, Karnes, Kendal, Kerr, McMullen, Medina, and Wilson)
• Austin (Includes counties: Travis, Williamson and Hays) 

NSGP-S. Eligible nonprofit organization subapplicants located outside of UASI-designated high-risk urban areas may apply to the SAA  to receive funding only under NSGP-S.

DHS/FEMA will verify that nonprofit sub-applicants have applied to the correct program and may disqualify the applications of nonprofit sub-applicants that apply to the wrong program.

Acronyms

• UASI – Urban Area Security Initiative
• NSGP-UA – Nonprofit Security Grant Program-Urban Area
• NSGP-S – Nonprofit Security Grant Program-State

Funding may be used for security or emergency planning expenses and the materials required to conduct planning activities. Planning must be related to the protection of the facility and the people within the facility and should include consideration of access and functional needs considerations as well as those with limited English proficiency.

• Development and enhancement of security plans and protocols;
• Development or further strengthening of security assessments;
• Emergency contingency plans;
• Evacuation/Shelter-in-place plans;
• Coordination and information sharing with fusion centers; and
• Other project planning activities with prior approval from FEMA.

Allowable costs are focused on target hardening and physical security enhancements. Funding can be used for the acquisition and installation of security equipment on real property (including buildings and improvements) owned or leased by the nonprofit organization, specifically in prevention of and/or protection against the risk of a terrorist attack. This equipment is limited to select items in the following two sections of items on the Authorized Equipment List (AEL):

• Physical Security Enhancement Equipment (Section 14); and
• Inspection and Screening Systems (Section 15).

In addition to the select items in Sections 14 and 15 listed above, the following equipment is also allowable:

• Notification and Warning Systems; and
• Radios and Public Warning Systems – Public Address, Handheld, or Mobile.

Funding may be used to conduct security-related exercises. This includes costs related to:

• Planning
• Meeting space and other meeting costs
• Facilitation costs
• Materials and supplies
• Documentation

Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets in a controlled, low risk setting.

Nonprofit organizations may use NSGP funds for the following training-related costs:

• Employed or volunteer security staff to attend security-related training within the United States;
• Employed or volunteer staff to attend security-related training within the United States with the intent of training other employees or members/congregants upon completing the training (i.e., “train-the-trainer” type courses); and
• Nonprofit organization’s employees, or members/congregants to receive on-site security training.

Allowable training topics are limited to the protection of critical infrastructure key resources, including physical and cybersecurity, target hardening, and terrorism awareness/employee preparedness. 

See the Preparedness Grants Manual, page C-6 for more details.

M&A costs are for activities directly related to the management and administration of the award.

M&A expenses must be based on actual expenses or known contractual costs. Requests that are simple percentages of the award, without supporting justification, will not be allowed or considered for reimbursement.

M&A expenses may not exceed 5% of the total project costs.

M&A costs include the following categories of activities:

• Hiring of full-time or part-time staff or contractors/consultants responsible for activities relating to the management and administration of NSGP funds. Hiring of contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327; and
• Meeting-related expenses directly related to M&A of NSGP funds.

POST AWARD REQUIREMENT: All funded projects with equipment installation must undergo an EHP Review to ensure compliance with EHP laws and NEPA.

EHP: Environmental/Historic Preservation

• Federal money cannot be used in a way that damages historic buildings
• Buildings 45 years or older can expect additional review

Note:  The EHP review and approval can be a multi-month approval process

NEPA: National Environmental Protection Act

• Federal government money can’t be used in a way that will harm the environment.
• This includes: air, water, animals, people, noise

Per the 2023 NSGP NOFO, both NSGP-UA and NSGP-S subapplicants may apply for up to $150,000 per site.  PSO will let applicants know if this amount changes for FY 2024.

Nonprofit organization may request funding for up to three (3) separate sites for a maximum of $450,000.

Physical location of the site to be protected determines eligibility under NSGP-UA or NSGP-S

Requests for multiple sites must be submitted through multiple applications to the SAA. One site per application.

• The term “site” indicates the physical location of one or more facilities to be protected.
• Multiple sites/locations requiring separate applications may be separated by physical location or addresses.
  
  Example: (Different Physical Address)
  
  A faith-based organization that maintains a house of worship and a school located with two separate street addresses regardless of distance.
  
  An organization that operates multiple schools spread across a geographical area, I.e., city, county, region, etc.
  
  Example: (Multiple sites/locations)
  
  An organization with a campus that includes several buildings/facilities with a shared physical address. Buildings are designated by a unique building number or other designation/name. E.g., a church and school with a shared physical address however the church is physically separate from the school.

The NSGP does not have a match requirement

Applicants are encouraged to request the maximum amount for each site.

Nonprofit Organizations applying to the SAA will need to prepare three documents for each site:

• Organization Mission Statement
• Site Vulnerability Assessment
• Investment Justification

Additional documentation needed include:

• Completed Texas Payee ID application
• Completed Direct Deposit Form
• Completed IRS W-9 Form

Organizations will also need to register in the federal System for Award Management (SAM) to secure a SAM UEI number. NOTE: There are no costs associated with SAM registration. Please be mindful for potential scams requesting payment to complete a SAM registration.

A mission statement is a formal summary of the aims and values of an organization. The three components of a mission statement include the purpose, values, and goals of the organization. The provided statement should discuss the “who, what, and why” of your organization.

A vulnerability assessment is used to identify and validate physical security deficiencies of your organization/facility and is the foundation of an NSGP application.

Currently there is no prescribed format or template for the assessment.

Vulnerability assessments can be provided in the form of a:

• Cybersecurity and Infrastructure Security Agency (CISA) Self-Assessment (Facility Security Self-Assessment | CISA), 
• State or Local Law Enforcement Assessment, 
• Contractor Assessment, or 
• other valid method of assessment.

The vulnerably assessment involves looking inside the organization for internal vulnerabilities and weaknesses. 

Projects/activities requested through the NSGP should align to mitigate items identified in the vulnerability assessment.