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Fiscal Year 2023 Nonprofit Security Grant Program (NSGP) Subapplicant Quick Start Guide

Release Date:
Février 27, 2023

The Department of Homeland Security (DHS) is firmly committed to ensuring that its funding opportunities and application processes are clear and transparent, and that they do not create confusion or contain undue complexity. DHS has endeavored to fulfill that commitment here, and we plan to take a series of concrete steps, in the future, to ensure that DHS continues to deliver on that commitment.

Nonprofit organizations should consider using this document as a reference when preparing applications for the Nonprofit Security Grant Program (NSGP).  

What is the NSGP?

The NSGP is a competitive grant program appropriated annually through the Department of Homeland Security (DHS) and administered by the Federal Emergency Management Agency (FEMA). It is intended to help nonprofit organizations increase their physical security posture against acts of terrorism or other extremist attacks. Eligible organizations are registered 501(c)(3) nonprofits or otherwise are organizations as described under 501(c)(3) of the Internal Revenue Code (IRC) and tax-exempt under section 501(a) of the IRC. This includes entities designated as “private” (e.g., private institutions of higher learning), as private colleges and universities can also be designated as 501c3 entities. More information on tax-exempt organizations can be found at: https://www.irs.gov/charities-non-profits/charitable-organizations.

Note: Publications and new program guidance are released periodically based on the current fiscal year. Please ensure that you have consulted the most current NSGP Notice of Funding Opportunity (NOFO) and Preparedness Grants Manual (PGM) thoroughly. Any publications from prior fiscal years, or published prior to the NOFO, should be used as historical references only since program priorities and requirements can change every year. Successful NSGP subrecipients must comply with all applicable requirements outlined in the NOFO and PGM.

How to Apply

To apply for NSGP funds, interested nonprofit organizations must apply through their State Administrative Agency (SAA). Each SAA has an established application submission process with a state-specific deadline to submit all required materials. The application submission deadline in the NOFO applies to the SAA only and is the deadline for the SAA to submit all administratively reviewed application materials to FEMA. You will need to contact your SAA point of contact on state-specific deadlines and supplemental application materials or requirements unique to your state or territory. The list of SAAs can be found at: https://www.fema.gov/grants/preparedness/state-administrative-agency-contacts. FEMA program support can be contacted by emailing fema-nsgp@fema.dhs.gov.

Nonprofit organizations must fully answer each question in all the sections of the Investment Justification(s) (IJ). In their Investment Justification (IJ), nonprofit organizations should summarize the most critically important, impactful, and salient information. You may submit up to three (3) Investment Justifications per funding stream (three for NSGP-State, three for NSGP-Urban Area), which function as an application document, per organization for up to six (6) unique physical locations/addresses. You must submit one (1) unique Investment Justification form and required documents as part of a complete submission package for each physical location/unique address. Each Investment Justification can request up to $150,000 per location with an upper limit per organization of $450,000 across six (6) Investment Justifications for six (6) unique physical locations/addresses. The amount of funding requested, and number of submissions, may not exceed these limits.

Nonprofit organizations must have a Unique Entity Identifier (UEI), which is obtained through SAM.gov. Nonprofit organizations are not required to have a UEI issued at the time of application but MUST have a valid UEI in order to receive a subaward from the SAA. Nonprofit organizations must register in SAM.gov to obtain the UEI but are not required to maintain an active registration in SAM.gov. Guidance on obtaining a UEI in SAM.gov can be found at GSA UEI Update and SAM.gov Update. It may take four weeks to obtain a UEI, and applicants should plan accordingly. Obtaining a UEI does not cost anything; it is free of charge.    

Tip: NSGP has two funding streams: NSGP-State (NSGP-S) and NSGP-Urban Area (NSGP-UA). Identify and apply for the proper funding stream (NSGP-S OR NSGP-UA) based on the physical geographical location/address of the facility and whether it is within a high-risk urban area. A full list of eligible high-risk urban areas is in the NSGP NOFO. The list of urban areas can change annually, and the final list of eligible urban areas is included in the NOFO for the corresponding fiscal year. Contact your SAA for questions about the appropriate funding stream based on your organization’s location. Applications submitted to the incorrect funding stream will not be considered.

Application Elements

The following materials, including any additional required or requested materials specific to the state or territory, must be submitted to the SAA as part of a complete application package. A submission that is missing any required document(s) will be considered incomplete and will not be reviewed.

Mission Statement

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.

Tip: It is highly recommended that the mission statement is documented on official letterhead. This element helps inform and validate a nonprofit organization’s categorical self-identification based on its ideology, beliefs, mission, function, or constituency served/supported.

Vulnerability Assessment

A vulnerability assessment is used to identify and validate physical security deficiencies of your organization/facility and is the foundation of an NSGP application. 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 SAA may require a specific format/type of vulnerability assessment, so be sure to review the state-specific guidelines for their application requirements. The vulnerably assessment is uniquely different from a risk/threat assessment: in essence, a risk assessment involves looking outside of an organization to determine external threats that exist that could potentially lead to security issues, whereas a vulnerability 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.

Tip: In preparation to describe how they intend to use NSGP grant funding, non-profit organizations should think broadly and holistically in their approach to security measures designed to protect buildings and safeguard people. Some physical security control examples include locks, gates, and guards (e.g., contract security). Although these may be effective measures, there are many additional layers to physical security that can help protect the organization, including creating comprehensive physical security plans, conducting training and exercises (e.g., active shooter, evacuation), identifying countermeasures against intrusion (e.g., access controls), preventing physical security breaches (e.g., security enhanced doors/windows), and monitoring for physical security threats (e.g., cameras, surveillance). Descriptions of allowable costs and activities can be located in the NOFO and the PGM. Unallowable costs will not be reimbursed.

Investment Justification (IJ)

The Investment Justification is a fillable template provided and required by FEMA made available through Grants.gov that asks nonprofits to describe the organization, risks/threats to the organization, and proposed projects/activities to mitigate security deficiencies (as identified in the vulnerability assessment) utilizing NSGP funding. The Investment Justification is published with the NOFO and is not available prior to the publication of the program materials. Please note, the Investment Justification is subject to change each fiscal year, and prior years’ templates will not be accepted. Only use the form for the current fiscal year as released on Grants.gov.

Supplemental Documents

Each state or territory is unique in how they manage and administer the NSGP. The SAA may require specific supplemental documents or templates in addition to those required by FEMA as part of the state or territory’s internal NSGP application submission requirement. However, when preparing the Investment Justification, organizations must answer questions completely and cannot rely on references to or cite page numbers of any supplemental documents as they are not submitted to nor reviewed by FEMA. Only the Investment Justification is submitted to FEMA by the SAA.

Tip: Contact your SAA for unique, state-specific submission requirements.

Scoring and Funding Recommendations

Upon submission of your completed application to the SAA, the state or territory will review, score, and rank every complete application it has received from eligible nonprofit organizations. The results of the scoring process will be forwarded to FEMA and will inform the federal review of the Investment Justifications based on the criteria outlined in the NSGP NOFO. Following the federal review and based on a combination of state or territory and federal scoring, nonprofit organizations are recommended for funding. The final list of recommended nonprofit organizations to be funded is provided to the Secretary of Homeland Security for final approval.

Bonus Points

Additional points are added to the final scores of applicants based on funding history and service to underserved, underrepresented, and/or marginalized populations. For applicants that have not received funding in the past, 15 additional points will be added to the final score. The Center for Disease Control’s (CDC) Social Vulnerability Index (SVI) is used to determine an organization’s relationship to underserved, underrepresented and/or marginalized populations. Organizations located in an area with a high (0.69 – 0.79) or very high (0.8 – 1) SVI score will have 10 or 15 bonus points added to final scores, respectively.

Investment Justification Checklist

Nonprofit organizations must fully answer each question in all the sections of the Investment Justification for the form to be considered complete. In their Investment Justification, nonprofit organizations should summarize the most critically important, impactful, and salient information. The Fiscal Year 2023 Investment Justification is the only document submitted to FEMA by the SAA and should be crafted using the identified threats/risks to your organization, the results of the vulnerability assessment of a physical location/structure/building, and details of the requested projects/activities to mitigate or remediate those vulnerabilities with associated estimated costs. Nonprofit organizations should describe their current threat/risk. While historic risk may be included for context, the Investment Justification should focus on current threats and risks.

Reminder: Applicants may submit up to six (6) Investment Justifications with one (1) unique Investment Justification form and required documents for each unique physical location/address. Each Investment Justification can request up to $150,000 per location, with an upper limit of $450,000 per organization across six (6) unique physical locations/addresses, with a maximum of three (3) submissions to each funding stream (NSGP-UA and NSGP-S). The amount of funding requested, and number of submissions, may not exceed these limits.

 

Below is the Investment Justification Checklist that includes the required contents of a complete NSGP Investment Justification:

Section 1 - Applicant Information

  • Legal Name of the Organization/Physical Address of the Facility/County
  • Owning vs. Leasing/Renting and Permission to Make Enhancements
  • Active Operation out of the Listed Location
  • Other Organizations in Facility
  • Mission Statement Summary
  • Organization Type
  • Organization Function
  • Organization’s Affiliation
  • 501(c)(3) Tax-Exempt Designation
  • Unique Entity Identifier (UEI) obtained via the System for Award Management (replaces DUNS)
  • Funding Stream
    • Designated high-risk urban area (if applicable)
  • Federal Funding Request (total estimated cost of projects/activities)

 Section 2 - Background

  • Describe the symbolic value of your organization’s site as a highly recognized national or historical institution, or significant institution within the community that renders the site a possible target of terrorist or extremist attack.
  • Describe any role in responding to or recovering from terrorist or other extremist attacks, specifically highlighting the efforts that demonstrate integration of nonprofit preparedness with broader state and local preparedness efforts.

Section 3 – Risk

  • Threat: Describe the identification and substantiation of specific threats, incidents, or attacks against the nonprofit organization or a closely related organization, network, or cell (examples include police report, insurance claim, internet threats, etc.).
  • Vulnerability: Describe your organization’s susceptibility to destruction, incapacitation, or exploitation by a terrorist or other extremist attack.
  • Consequence: Describe potential negative effects/impacts on your organization’s assets, systems, and/or function if disrupted, damaged, or destroyed due to a terrorist or extremist attack.

Section 4 – Facility Hardening

  • Describe how the proposed projects/activities will harden (make safer/more secure) the facility and/or mitigate the identified risk(s) and/or vulnerabilities based on the vulnerability assessment.
  • Describe how the proposed target hardening focuses on the prevention of and/or protection against the risk/threat of a terrorist or other extremist attack.
  • Confirm that the proposed projects are allowable in accordance with the priorities of the NSGP (NOFO, PGM).
  • Confirm that the proposed projects are feasible (meaning there is a reasonable expectation based on predicable planning assumptions to complete all tasks, projects and/or activities within the subaward period of performance) and proposed milestones under the NSGP.

 Section 5 – Milestones

  • Describe any key activities that will lead to milestones in the program/project and grants management over the course of the NSGP grant award period of performance.
    • NOTE: Anything involving modifications to a building or site will likely require EHP review. In that case, it should be one of the first milestones.

Section 6 – Project Management

  • Describe the proposed management team’s roles, responsibilities, and governance structure to support the implementation of the projects/activities.
  • Assess the project management plan/approach.

Section 7 – Impact

  • Describe the outcome and outputs of the proposed projects/activities that will indicate that the investment was successful.

Funding History

  • Include past funding amounts and projects under NSGP.

 

Definitions

  • Vulnerability Assessment: The vulnerability assessment is a documented review of your facility that identifies gaps in security. Addressing gaps as they are identified in the vulnerability assessment keeps a facility and its occupants, visitors, or members safer. This document is the foundation of an NSGP application.
  • Underserved Communities or Populations: Includes communities and populations who traditionally face barriers in accessing and using publicly available resources, including those underserved because of geographic location, religion, sexual orientation, gender identity, underserved racial and ethnic populations, underserved because of special needs (such as language barriers, disabilities, alienage status, or age), and any other community or population determined to be underserved by the Secretary of the Department of Homeland Security (DHS), as appropriate.
  • Subapplicant/Subrecipient: Individual nonprofit organizations are considered the subapplicants or the subrecipients of the NSGP grant. The SAA is the primary applicant and recipient. Each nonprofit organization must individually submit an application to their SAA, which will then submit it to FEMA for consideration, but the award itself will be made directly to the state or territory’s SAA. The SAA will then manage the grant and be the main point of contact for the nonprofit organizations for everything related to their grant award.
  • Period of Performance: The period of performance is the length of time that recipients and subrecipients have to implement their project(s), accomplish all goals, and expend all grant funding. The period of performance under the NSGP is 36 months for the SAAs. However, given that the SAA has a high level of administrative burden in managing the NSGP, typically a shorter period of performance than 36 months is given to nonprofit subrecipients. There may be situational extensions to the period of performance based on undue hardships, but recipients and subrecipients should not assume any extensions will be granted and plan for full project completion within the designated period of performance. All costs must be incurred, and all services or goods must be completed or delivered within the period of performance. Unless the subrecipient and SAA have requested and received approval from FEMA for pre-award costs, any expenditures made prior to official notification of award from the SAA and before the start of the subrecipient’s period of performance will be considered unallowable.
  • High-risk Urban Area: High-risk urban areas are metropolitan locations designated in FEMA’s Urban Area Security Initiative (UASI) program each year based on the 100 most populous metropolitan statistical areas (MSAs). Nonprofit organizations with physical locations in one of those high-risk urban areas are eligible under the NSGP-Urban Area (UA) program; all other nonprofits are eligible under the NSGP-State (S) program. The list of high-risk urban areas under UASI changes every year based on risk. A list of eligible high-risk urban areas will be included in each year’s NSGP NOFO. Because high-risk urban areas often extend beyond the local city limits and because the localities included within the corresponding MSA are not always included in the high-risk urban area, contact your SAA to confirm whether your organization is located within a designated high-risk urban area for the purposes of the NSGP-UA program. If a nonprofit does not apply for the correct funding stream based on location, the application will be automatically eliminated.
  • State Administrative Agency (SAA): SAAs are the designated state and territory offices that manage the NSGP awards. These offices are the primary applicants to FEMA and recipients from FEMA of NSGP funds. The SAA will make NSGP subawards to subrecipients (e.g., nonprofit organizations).
  • Risk: Potential for an adverse outcome assessed as a function of hazard/threats, assets and their vulnerabilities, and consequence. In the context of NSGP applications, nonprofit organizations should describe their current threat/risk of terroristic or other extremist attack and how those identified vulnerabilities (in the vulnerability assessment) could potentially be exploited.
  • Threat: Indication of potential harm to life, information, operations, the environment and/or property; may be a natural or human-created occurrence and considers capabilities, intentions, and attack methods of adversaries used to exploit circumstances or occurrences with the intent to cause harm.
  • Vulnerability: Physical feature or operational attribute that renders an entity open to exploitation or susceptible to a given hazard; includes characteristic of design, location, security posture, operation, or any combination thereof, that renders an asset, system, network, or entity susceptible to disruption, destruction, or exploitation.
  • Consequence: Effect of an event, incident, or occurrence; commonly measured in four ways: human, economic, mission, and psychological, but may also include other factors such as impact on the environment.
  • Terrorism: Any activity that:
    1. Involves an act that: A) is dangerous to human life or potentially destructive of critical infrastructure or key resources; and B) is a violation of the criminal laws of the United States or of any State or other subdivision of the United States; and
    2. Appears to be intended to: A) intimidate or coerce a civilian population; B) influence a policy of a government by intimidation or coercion; or C) affect the conduct of a government by mass destruction, assassination, or kidnapping.

Additional definitions can be found in the DHS Lexicon Terms and Definitions.

Resources

This section contains a list of resources that NSGP applicants may find useful in the development of their Investment Justifications. Potential applicants can use the links listed below to access information and resources that can assist in the NSGP application process and project implementation. Resources referring to prior fiscal years are provided for historical reference only.

DHS FEMA, Grant Programs Directorate

DHS Cybersecurity and Infrastructure Security Agency (CISA)

DHS Center for Faith-Based and Neighborhood Partnerships

DHS Office for Civil Rights & Civil Liberties (CRCL)

DHS Center for Prevention, Programs and Partnerships (CP3)

Department of Justice (DOJ) Community Relations Service (CRS)

U.S. Department of Education

DHS Office of Intelligence & Analysis (I&A)

Federal Bureau of Investigation (FBI)

Other Resources

 

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