The U. S. Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) Fiscal Year 2024 Nonprofit Security Grant Program

Download the NOFO.

The U.S. Department of Homeland Security 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. Throughout this funding notice, the term “applicant” refers to the State Administrative Agency (SAA), and the term “subapplicant” refers to the nonprofit organization. Consistent with the commitment to clarity and transparency, most of this NOFO’s information identifies actions for the applicant to take, not the subapplicant. Interested persons with questions about what is required should consult Nonprofit Security Grant Program | FEMA.gov, email FEMA-NSGP@fema.dhs.gov, or call FEMA Grants News at (800) 368-6498, Monday through Friday, 9:00 AM – 5:00 PM ET

All entities wishing to do business with the federal government must have a unique entity identifier (UEI). The UEI number is issued by the system. Requesting a UEI using System for Award Management (SAM.gov) can be found at: https://sam.gov/content/entity-registration. 

Updates in Grant Application Forms:
The Data Universal Numbering System (DUNS) Number was replaced by a new, non-proprietary identifier requested in, and assigned by SAM.gov. This new identifier is the Unique Entity Identifier.

Additional Information can be found on Grants.gov: https://www.grants.gov/forms/forms-development/planned-uei-updates. 

Table of Contents

Updates in Grant Application Forms

A. Program Description

1. Issued By
2. Assistance Listings Number
3. Assistance Listings Title
4. Funding Opportunity Title
5. Funding Opportunity Number
6. Authorizing Authority for Program
7. Appropriation Authority for Program
8. Announcement Type
9. Program Category
10. Program Overview, Objectives, and Priorities
11. Performance Measures

B. Federal Award Information

1. Available Funding for the NOFO:    $274,500,000
2. Projected Number of Awards: 56
3. Maximum Award Amount:
4. Period of Performance:      36 months
5. Projected Period of Performance Start Date(s):   09/01/2024
6.  Projected Period of Performance End Date(s): 08/31/2027
7. Funding Instrument Type:     Grant

C. Eligibility Information

1. Eligible Applicants
2.  Applicant Eligibility Criteria
3. Subawards and Beneficiaries
4. Other Eligibility Criteria
5. Cost Share or Match

D. Application and Submission Information

1. Key Dates and Times
2. Agreeing to Terms and Conditions of the Award
3. Address to Request Application Package
4. Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management (SAM)
5. Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management (SAM), and Submit an Application
6. Electronic Delivery
7. How to Register to Apply
8. Submitting the Application
9. Timely Receipt Requirements and Proof of Timely Submission
10. Content and Form of Application Submission
11. Intergovernmental Review
12. Funding Restrictions and Allowable Costs

E. Application Review Information

1. Application Evaluation Criteria
2. Review and Selection Process

F. Federal Award Administration Information

1. Notice of Award
2. Pass-Through Requirements
3.  Administrative and National Policy Requirements
4. Reporting
5. Monitoring and Oversight

G. DHS Awarding Agency Contact Information

1. Contact and Resource Information
2. Systems Information

H. Additional Information

1. Unique Entity Identifier
2. Program Evaluation
3. Period of Performance Extensions
4. Protecting Houses of Worship and Public Venues
5. Financial Assistance Programs for Infrastructure

Appendix A: Evaluation Criteria and Scoring

A.     Program Description

1. Issued By

U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA)/Grant Programs Directorate (GPD)

2.   Assistance Listings Number

97.008

3.   Assistance Listings Title

Nonprofit Security Grant Program

4.   Funding Opportunity Title

Fiscal Year 2024 Nonprofit Security Grant Program (NSGP)

5.   Funding Opportunity Number

DHS-24-GPD-008-00-99

6.   Authorizing Authority for Program

Section 2009 of the Homeland Security Act of 2002 (Pub. L. No. 107-296, as amended) (6 U.S.C. 609a)

7.   Appropriation Authority for Program

Department of Homeland Security Appropriations Act, 2024, Pub. L. No. 118-47, Title III, Protection, Preparedness, Response, and Recovery (2024 DHS Appropriations Act)

8.   Announcement Type

Initial

9.   Program Category

Preparedness: Community Security 

10. Program Overview, Objectives, and Priorities

a. Overview

The Fiscal Year (FY) 2024 Nonprofit Security Grant Program (NSGP) is one of three grant programs that support DHS/FEMA’s focus on enhancing the ability of state, local, tribal, and territorial governments, as well as nonprofits, to prevent, protect against, prepare for, and respond to terrorist or other extremist attacks. These grant programs are part of a comprehensive set of measures authorized by Congress and implemented by DHS to help strengthen the nation’s communities against potential terrorist or other extremist attacks. NSGP applicants include the State Administrative Agencies (SAA), and subapplicants include eligible nonprofit organizations. See Section C.3 “Subrecipient Eligibility” for more information.

In FY 2024, there are two funding sources appropriated for nonprofit organizations:

1. NSGP - Urban Area (NSGP-UA): NSGP-UA funds nonprofit organizations located within FY 2024 Urban Area Security Initiative (UASI)-designated high-risk urban areas; and
2. NSGP - State (NSGP-S): NSGP-S funds nonprofit organizations located outside of a FY 2024 UASI-designated high-risk urban area. Under NSGP-S, each state will receive a target allocation for nonprofit organizations in the state located outside of FY 2024 UASI-designated high-risk urban areas.

For FY 2024, DHS is focused on building a national culture of preparedness and protecting against terrorism and other threats to our national security. The threats to our Nation have evolved during the past two decades. We now face continuous cyber threats by sophisticated actors, threats to soft targets and crowded places, and threats from domestic violent extremists, who represent one of the most persistent threats to the nation today. Therefore, DHS/FEMA has identified one national priority area related to some of the most serious threats that recipients should address with their NSGP funds: enhancing the protection of soft targets/crowded places. 

DHS is also focused on forging partnerships to strengthen information sharing and collaboration among federal, state, local, tribal, and territorial law enforcement. There are no requirements for information sharing between nonprofit organizations and law enforcement; however, the NSGP seeks to bring nonprofit organizations into broader state and local preparedness efforts by removing barriers to communication and being more inclusive. DHS/FEMA encourages information sharing, while the goal of the NSGP is centered on improving and increasing a nonprofit organization’s physical/cyber security and facility/target hardening to enhance the protection of soft targets/crowded places. All NSGP activities must be linked to enhancing the security and safety at the physical site of the nonprofit organization.

For FY 2023, 5,257 applications were received by FEMA and 2,201 subrecipients were approved for funding. For a list of funding broken out by state and urban area, please refer to Information Bulletin (IB) 490a.

b. Goal, Objectives, and Priorities

Goal: The NSGP will improve and increase the physical/cyber security and facility/target hardening of nonprofit organizations’ facilities at risk of a terrorist of other extremist attack, ultimately safeguarding the lives and property of the American people. All NSGP activities must be linked to enhancing the security and safety at the physical site of the nonprofit organization. Concurrently, the NSGP will integrate the preparedness activities of nonprofit organizations that are at high risk of a terrorist or other extremist attack with broader state and local preparedness efforts.

Objectives: The objective of the FY 2024 NSGP is to provide funding for physical and cybersecurity enhancements and other security-related activities to nonprofit organizations that are at high risk of a terrorist or other extremist attack within the period of performance. The NSGP also seeks to integrate the preparedness activities of nonprofit organizations with broader state and local preparedness efforts. Lastly, via funding spent on Planning, Organizational, Equipment, Training, and Exercises (POETE) towards enhancing the protection of soft targets and crowded places, the NSGP seeks to address and close capability gaps identified in individual nonprofit organization Vulnerability Assessments. 

Priorities: Given the evolving threat landscape, DHS/FEMA has evaluated the national risk profile and set priorities that help ensure appropriate allocation of scarce security dollars. In assessing the national risk profile for FY 2024, one area warrants the most concern under the NSGP:

• Enhancing the protection of soft targets/crowded places.

Likewise, there are several enduring security needs that crosscut the homeland security enterprise. The following are second-tier priority areas that help recipients implement a comprehensive approach to securing communities:

1. Effective planning;
2. Training and awareness campaigns; and
3. Exercises.

A continuing area of concern is the threat posed by malicious cyber actors. Additional resources and information regarding cybersecurity and cybersecurity performance goals are available through the Cybersecurity and Infrastructure Security Agency, Cross-Sector Cybersecurity Performance Goals, and the National Institute of Standards and Technology. 

The table below provides a breakdown of these priority areas for the FY 2024 NSGP, showing both the core capabilities enhanced and lifelines supported, as well as examples of eligible project types for each area. More information on allowable investments can be found in the Funding Restrictions and Allowable Costs section below. 

FY 2024 NSGP Funding Priorities

All priorities in this table concern the Safety and Security Lifelines.

National Priorities

Enduring Needs

c. Alignment to Program Purpose and the DHS and FEMA Strategic Plan

Among the five basic homeland security missions noted in the DHS Strategic Plan for Fiscal Years 2020-2024, NSGP supports the goal to Strengthen National Preparedness and Resilience.

The 2022-2026 FEMA Strategic Plan outlines three bold, ambitious goals in order to position FEMA to address the increasing range and complexity of disasters, support the diversity of communities we serve, and complement the nation’s growing expectations of the emergency management community. The NSGP supports FEMA’s efforts to instill equity as a foundation of emergency management (Goal 1), as well as promote and sustain a ready FEMA and prepared nation (Goal 3). We invite our stakeholders and partners to also adopt these priorities and join us in building a more prepared and resilient nation.

11. Performance Measures

The performance metric for this program is:

• Percentage of funding awarded to the Soft Targets/Crowded Places national priority area by POETE (Planning, Organization, Equipment, Training, and Exercise) solution area, which includes:
  • Funding awarded for contract security; 
  • Funding awarded for target hardening; 
  • Funding awarded for cybersecurity measures; and 
  • Funding awarded for training, awareness campaigns, and exercises. 

As noted in the NSGP’s objectives in Section A.10.b, via funding spent on POETE towards enhancing the protection of soft targets and crowded places, the NSGP seeks to address and close capability gaps identified in individual nonprofit organization Vulnerability Assessments. FEMA will calculate and analyze the above metrics through a review of recipient Biannual Strategy Implementation Report updates and award monitoring to ensure that the funds are expended for their intended purpose and achieve the stated outcomes in the grant application.

B.  Federal Award Information

Available Funding for the NOFO:                              $274,500,000

Subtotal for NSGP-UA:                                           $137,250,000 

Subtotal for NSGP-S:                                               $137,250,000

2.   Projected Number of Awards:                                          56

3.   Maximum Award Amount:

Nonprofit organizations must apply through their respective SAA. See Section C.1 “Eligible Applicants” for more information about the SAA, nonprofit organization, and applicant/subapplicant roles and responsibilities. For NSGP-UA and NSGP-S, consistent with prior years, each nonprofit organization may only represent one site/location/physical address per application. For example, a nonprofit organization with one site may apply for up to $150,000 for that site. 

Nonprofit organizations with multiple sites/locations/physical addresses may choose to apply for additional sites for up to $150,000 per site, for a maximum of three sites per funding stream, not to exceed $450,000 total per state. That is, a nonprofit organization with sites in both NSGP-S and NSGP-UA areas in a given state may apply for a total of up to six sites, but the total of their applications cannot exceed $450,000. A nonprofit organization subapplicant may not exceed a total of six applications (three for NSGP-S and three for NSGP-UA) for a total of $450,000 per state. A nonprofit organization with locations in multiple states may apply for up to three sites within each state and funding stream (three for NSGP-S and three for NSGP-UA per state). Section C.2 provides a table of the eligible Urban Areas for FY 2024 that would apply to the NSGP-UA funding stream. All other nonprofit organizations outside of these Urban Areas apply to the NSGP-S program.

If a nonprofit subapplicant applies for projects at multiple sites, regardless of whether the projects are similar in nature, each individual site must include an assessment of the vulnerability and risk unique to each site. That is, one vulnerability assessment per location/physical address. Failure to do so may be cause for rejection of the application. 

4.   Period of Performance:                                                                 36 months

Extensions to the period of performance are allowed. For additional information on period of performance extensions, please refer to the Preparedness Grants Manual (FM-207-23-001).

5.   Projected Period of Performance Start Date(s):         09/01/2024

6.   Projected Period of Performance End Date(s):          08/31/2027

7.  Projected Budget Period(s)

There will be only a single budget period with the same start and end dates as the period of performance. 

8.  Funding Instrument Type:                                                      Grant

C.  Eligibility Information

1. Eligible Applicants

Note: Throughout this funding notice, the term “applicant” refers to the SAA, and the term “subapplicant” refers to the nonprofit organization. Consistent with the commitment to clarity and transparency, most of this NOFO’s information identifies actions for the applicant to take, not the subapplicant. Contact FEMA-NSGP@fema.dhs.gov with questions.

The 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 FY 2024 NSGP through their SAA, who then submits application information to FEMA. A list of SAA points of contact is available at: State Administrative Agency (SAA) Contacts | FEMA.gov. Nonprofit organizations may NOT apply directly to DHS/FEMA for FY 2024 NSGP funds. 

Additional information on the subapplicant process specific to nonprofit organizations is included in Section D.10 “Content and Form of Application Submission” of this funding notice. 

SAAs, in coordination with the Urban Area Working Groups (UAWG) or other relevant state partners, are encouraged to notify and actively inform eligible nonprofit organizations of the availability of FY 2024 NSGP funding. 

2.   Applicant Eligibility Criteria

The SAA is the only eligible applicant. 

An application submitted by an otherwise eligible non-federal entity (which for this program is the SAA) may be deemed ineligible when the person that submitted the application (for the applicant/SAA) is not: 1) a current employee, personnel, official, staff, or leadership of the non-federal entity; and 2) duly authorized to apply for an award on behalf of the non-federal entity at the time of application. Further, the Authorized Organization Representative (AOR) must be a duly authorized current employee, personnel, official, staff or leadership of the recipient and provide an email address unique to the recipient (SAA) at the time of application and upon any change in assignment during the period of performance. Consultants or contractors of the recipient are not permitted to be the AOR of the recipient.

FY 2024 NSGP-UA Eligible High-Risk Urban Areas

FY 2024 NSGP-S Target Allocations

a. Reducing Subapplicant Burden

For FY 2024, each SAA is strongly encouraged to re-evaluate its process for collecting and evaluating subaward applications. FEMA encourages each SAA to minimize the type and quantity of information that it collects as part of the subaward application process, in order to decrease the overall financial and time burden associated with applying for subawards under this grant program. Each SAA should review its subaward application and reduce or eliminate the request for any information that is not needed for legal, financial, or oversight purposes. 

3. Subawards and Beneficiaries

a. Subaward Allowability

Subawards are allowed under the NSGP. The recipient (the SAA) is awarded, and then all funds to the nonprofit organizations (subrecipients) are considered subawards. 

b. Subrecipient Eligibility

Nonprofit organizations eligible as subapplicants to the SAA are those organizations that are:

1. Described under section 501(c)(3) of the Internal Revenue Code of 1986 (IRC) and exempt from tax under section 501(a) of such code. 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.

Note: The Internal Revenue Service (IRS) does not require certain organizations such as churches, mosques, and synagogues to apply for and receive a recognition of exemption under section 501(c)(3) of the IRC. Such organizations are automatically exempt if they meet the requirements of section 501(c)(3). These organizations are not required to provide recognition of exemption. For organizations that the IRS requires to apply for and receive a recognition of exemption under section 501(c)(3), the state may or may not require recognition of exemption, as long as the method chosen is applied consistently. 

Refer to links below for additional information: 

• Exemption Requirements - 501(c)(3) Organizations | Internal Revenue Service (irs.gov) 
• Publication 557 (01/2022), Tax-Exempt Status for Your Organization | Internal Revenue Service (irs.gov)
• Charities and Nonprofits | Internal Revenue Service (irs.gov)

2. Able to demonstrate, through the application, that the organization is at high risk of a terrorist or other extremist attack; and
3. For NSGP-UA, located within a FY 2024 UASI-designated high-risk urban area; or for NSGP-S, located outside of a FY 2024 UASI-designated high-risk urban area. 

Examples of eligible subapplicant organizations can include houses of worship, museums, educational facilities, senior centers, community centers, and day camps, among many others. 

Applying for NSGP-UA versus NSGP-S 

Nonprofit organizations may NOT apply to FEMA directly. Nonprofit organizations must apply for FY 2024 NSGP through their SAA. A list of SAA points of contact is available at State Administrative Agency (SAA) Contacts | FEMA.gov. Nonprofit organizations should contact the respective SAA to:

• Verify the SAA’s application deadline. SAAs establish all requirements and deadlines to manage their nonprofit sub-application process in support of the SAAs’ submissions to DHS/FEMA. Deadlines and state requirements may vary from state to state. The deadline published in this funding notice is for the SAA to apply to DHS/FEMA, not for the nonprofit organization to apply to the SAA.
• Obtain information on any additional state requirements or processes.

Eligible nonprofit subapplicants located within FY 2024 UASI-designated high-risk urban areas may apply to the SAA (applicant) to receive funding only under NSGP-UA. Eligible nonprofit organization subapplicants located outside of FY 2024 UASI-designated high-risk urban areas may apply to the SAA (applicant) to receive funding only under NSGP-S. DHS/FEMA will verify that nonprofit subapplicants have applied to the correct program and may disqualify the applications of nonprofit subapplicants that apply to the wrong program.

For nonprofit organizations that are unsure if they are within a FY 2024 UASI-designated urban area, contact the respective SAA. A list of SAA contacts can be found at State Administrative Agency (SAA) Contacts | FEMA.gov. 

If a nonprofit organization has a physical location within a defined Metropolitan Statistical Area but the location is NOT within the bounds of how the UAWG defines the high-risk urban area footprint for the purposes of the UASI grant program, then that location should apply under NSGP-S.

Nonprofit organizations that have locations both within and outside of UASI-designated high-risk urban areas can apply under both NSGP-UA and NSGP-S depending on the physical location of the facilities. In such cases, the nonprofit subapplicant must submit separate applications for NSGP-UA and NSGP-S to the SAA (applicant) for funding consideration. SAA applicants and nonprofit subapplicants must still adhere to the other restrictions and requirements set forth in this funding notice, including applying for a maximum of six locationstotal per nonprofit organization with no more than three locations in either NSGP-UA or NSGP-S, and a maximum of $150,000 per location. If a nonprofit organization has a physical location within a defined Metropolitan Statistical Area but the location is NOT within the bounds of how the UAWG defines the high-risk urban area footprint for the purposes of the UASI grant program, then that location should apply under NSGP-S. Nonprofit organizations should contact their SAAs to determine if their physical location falls within the UAWG-defined high-risk urban area footprint.

Additionally, the final beneficiary of the NSGP grant award must be an eligible nonprofit organization and cannot be a for-profit/fundraising extension of a nonprofit organization. While these for-profit or fundraising extensions may be associated with the eligible nonprofit organization, NSGP funding cannot be used to benefit those extensions and therefore they will be considered ineligible applications. If the funding being sought is for the benefit of a for-profit/fundraising extension, then that would constitute an ineligible subaward since only nonprofit organizations are eligible subrecipients. This is distinct from a contract under an award in which a nonprofit organization could seek the assistance of a for-profit/fundraising extension, but the purpose would be to benefit the nonprofit organization and not for the benefit of the for-profit/fundraising extension. For further information on the distinction between a subaward and contract, see 2 C.F.R. § 200.331.

Other Subaward Information

Please see the following sections for additional information on requirements or restrictions related to subawards/subrecipients:

• Section D.4 “Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management”;
• Section D.12 “Funding Restrictions and Allowable Costs”;
• Section E.1 “Application Evaluation Criteria”;
• Section E.2 “Review and Selection Process”;
• Section F.4.b “Ensuring the Protection of Civil Rights”;
• Section F.6 “Monitoring and Oversight”;
• Section G.1.f “Environmental Planning and Historic Preservation”;
• Section H.1 “Terminations Provisions”;
• Section H.2 “Program Evaluation.”; and
• Section H.3 “Financial Assistance Programs for Infrastructure.”

Additionally, please see the Preparedness Grants Manual for further information on requirements or restrictions related to subawards/subrecipients.

d. Beneficiaries or Participants

This NOFO and any subsequent federal awards create no rights or causes of action for any participant or beneficiary.

4. Other Eligibility Criteria/Restrictions 

a.   National Incident Management System (NIMS) Implementation 

Prior to allocation of any federal preparedness awards, recipients (the SAA) must ensure and maintain adoption and implementation of NIMS. The list of objectives used for progress and achievement reporting is on FEMA’s website at https://www.fema.gov/emergency-managers/nims/implementation-training.

Please see the Preparedness Grants Manual for more information on NIMS.

5.   Cost Share or Match

There is no cost share requirement for the FY 2024 NSGP. Applicants/subapplicants that propose a cost share will not receive additional consideration in the scoring. 

D.  Application and Submission Information

Key Dates and Times

a.         Application Start Date:                       04/16/2024

b.         Application Submission Deadline:     06/24/2024 at 5 p.m. ET

All applications must be received by the established deadline. 

The SAA application deadline to apply to FEMA is June 24, 2024, at 5 p.m. ET. Nonprofit applications are due to the SAA BEFORE the application submission deadline for the SAA. Nonprofit organizations must contact the SAA for the state/territory deadline. SAAs establish all requirements and deadlines to manage their nonprofit sub-application process in support of their submissions to DHS/FEMA. Deadlines and SAA requirements may vary from state/territory to state/territory. Section D, in the subsection “Content and Form of Application Submission”, contains information specific for the nonprofit organization subapplicant process as it relates to FEMA NSGP application requirements. However, nonprofit organizations must work with their SAAs to determine state/territory-specific application requirements and deadlines.

FEMA’s Grants Outcomes System (FEMA GO) automatically records proof of timely submission and the system generates an electronic date/time stamp when FEMA GO successfully receives the application. The individual with the AOR role that submitted the application will also receive the official date/time stamp and a FEMA GO tracking number in an email serving as proof of their timely submission. For additional information on how an applicant will be notified of application receipt, see the subsection titled “Timely Receipt Requirements and Proof of Timely Submission” in Section D of this NOFO.

FEMA will not review applications that are received after the deadline or consider these late applications for funding. FEMA may, however, extend the application deadline on request for any applicant who can demonstrate that good cause exists to justify extending the deadline. Good cause for an extension may include technical problems outside of the applicant’s control that prevent submission of the application by the deadline, other exigent or emergency circumstances, or statutory requirements for FEMA to make an award. 

Applicants experiencing technical problems outside of their control must notify FEMA as soon as possible and before the application deadline. Failure to timely notify FEMA of the issue that prevented the timely filing of the application may preclude consideration of the award. “Timely notification” of FEMA means the following: prior to the application deadline and within 48 hours after the applicant became aware of the issue.

A list of FEMA contacts can be found in Section G of this NOFO, “DHS Awarding Agency Contact Information.” For technical assistance with the FEMA GO system, please contact the FEMA GO Helpdesk at femago@fema.dhs.gov or (877) 585-3242, Monday through Friday, 9:00 AM – 6:00 PM Eastern Time (ET). For programmatic or grants management questions, please contact your Preparedness Officer or Grants Management Specialist. If applicants do not know who to contact or if there are programmatic questions or concerns, please contact fema-grants-news@fema.dhs.gov, Monday through Friday, 9:00 AM – 5:00 PM ET.

c.   Anticipated Funding Selection Date:                   No later than August 23, 2024

d.   Anticipated Award Date:                                     No later than September 30, 2024

e.   Other Key Dates:

2.   Agreeing to Terms and Conditions of the Award

By submitting an application, applicants agree to comply with the requirements of this NOFO and the terms and conditions of the award, should they receive an award.

3.   Address to Request Application Package

Applications are processed through the FEMA GO system. To access the system, go to https://go.fema.gov/.

4.   Requirements: Obtain a Unique Entity Identifier (UEI) and Register in the System for Award Management (SAM.gov) 

Each applicant, unless they have a valid exception under 2 CFR §25.110, must:

1. Be registered in Sam.Gov before application submission. 
2. Provide a valid UEI in its application.
3. Continue to always maintain an active SAM registration with current information during the federal award process. Note: Per 2 C.F.R. § 25.300, subrecipients are NOT required to go through the full SAM registration process. First-tier subrecipients (meaning entities receiving funds directly from the recipient) are only required to obtain a UEI through SAM, but they are not required to complete the full SAM registration in order to obtain a UEI. Recipients may not make subawards unless the subrecipient has obtained and provided the UEI.

Lower-tier subrecipients (meaning entities receiving funds passed through by a higher-tier subrecipient) are not required to have a UEI and are not required to register in SAM. Applicants (the SAA) are also not permitted to require subrecipients (nonprofit organizations awarded NSGP funding) to complete a full registration in SAM beyond obtaining the UEI.

5.   Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management (SAM), and Submit an Application

Applying for an award under this program is a multi-step process and requires time to complete. Applicants are encouraged to register early as the registration process can take four weeks or more to complete. Therefore, registration should be done in sufficient time to ensure it does not impact your ability to meet required submission deadlines. 

Please review the table above for estimated deadlines to complete each of the steps listed. Failure of an applicant to comply with any of the required steps before the deadline for submitting an application may disqualify that application from funding.

To apply for an award under this program, all applicants must:

1. Apply for, update, or verify their UEI number and Employer Identification Number (EIN) from the Internal Revenue Service; 
2. In the application, provide an UEI number;
3. Have an account with login.gov; 
4. Register for, update, or verify their SAM account and ensure the account is active before submitting the application;
5. Register in FEMA GO, add the organization to the system, and establish the AOR. The organization’s electronic business point of contact (EBiz POC) from the SAM registration may need to be involved in this step. For step-by-step instructions, see https://www.fema.gov/grants/guidance-tools/fema-go/startup;
6. Submit the complete application in FEMA GO; and
7. Continue to maintain an active SAM registration with current information at all times during which it has an active federal award or an application or plan under consideration by a federal awarding agency. As part of this, applicants must also provide information on an applicant’s immediate and highest-level owner and subsidiaries, as well as on all predecessors that have been awarded federal contracts or federal financial assistance within the last three years, if applicable.

Applicants are advised that FEMA may not make a federal award until the applicant has complied with all applicable SAM requirements. Therefore, an applicant’s SAM registration must be active not only at the time of application, but also during the application review period and when FEMA is ready to make a federal award. Further, as noted above, an applicant’s or recipient’s SAM registration must remain active for the duration of an active federal award. If an applicant’s SAM registration is expired at the time of application, expires during application review, or expires any other time before award, FEMA may determine that the applicant is not qualified to receive a federal award and use that determination as a basis for making a federal award to another applicant.

Per 2 C.F.R. § 25.110(c)(2)(iii), if an applicant is experiencing exigent circumstances that prevents it from obtaining an UEI number and completing SAM registration prior to receiving a federal award, the applicant must notify FEMA as soon as possible by contacting fema-grants-news@fema.dhs.gov and providing the details of the circumstances that prevent completion of these requirements. If FEMA determines that there are exigent circumstances and FEMA has decided to make an award, the applicant will be required to obtain an UEI number, if applicable, and complete SAM registration within 30 days of the federal award date. 

6.   Electronic Delivery

DHS is participating in the Grants.gov initiative to provide the grant community with a single site to find and apply for grant funding opportunities. DHS encourages or requires applicants to submit their applications online through Grants.gov, depending on the funding opportunity. 

For this funding opportunity, FEMA requires applicants (the SAAs only) to submit applications through FEMA GO.

7.   How to Register to Apply

a.   General Instructions: 

Registering and applying for an award under this program is a multi-step process and requires time to complete. Read the instructions below about registering to apply for FEMA funds. Applicants should read the registration instructions carefully and prepare the information requested before beginning the registration process. Reviewing and assembling the required information before beginning the registration process will alleviate last-minute searches for required information.

The registration process can take up to four weeks to complete. To ensure an application meets the deadline, applicants are advised to start the required steps well in advance of their submission.

Applicants must have an UEI number, an EIN, and an active SAM registration to apply for a federal award under this funding opportunity.

b.   Obtain an UEI Number: 

All entities applying for funding, including renewal funding, must have a UEI number. Applicants (the SAAs) must enter the UEI number in the applicable data entry field on the SF-424 form.

For more detailed instructions for obtaining a UEI number, refer to: SAM.gov. 

c.   Obtain Employer Identification Number

All entities applying for funding must provide an Employer Identification Number (EIN). The EIN can be obtained from the IRS by visiting: https://www.irs.gov/businesses/small-businesses-self-employed/apply-for-an-employer-identification-number-ein-online. 

d.   Create a login.gov account: 

Applicants must have a login.gov account in order to register with SAM or update their SAM registration. Applicants can create a login.gov account here: https://secure.login.gov/sign_up/enter_email?request_id=34f19fa8-14a2-438c-8323-a62b99571fd3. 

Applicants only have to create a login.gov account once. For applicants that are existing SAM users, use the same email address for the login.gov account as with SAM.gov so that the two accounts can be linked.

For more information on the login.gov requirements for SAM registration, refer to: https://www.sam.gov/SAM/pages/public/loginFAQ.jsf. 

e.   Register with SAM: 

All applicants applying online through FEMA GO must register with SAM. Failure to register with SAM will prevent an applicant from completing the application in FEMA GO. SAM registration must be renewed annually. Organizations will be issued a UEI number with the completed SAM registration.

For more detailed instructions for registering with SAM, refer to:
https://apply07.grants.gov/help/html/help/Register/RegisterWithSAM.htm.

Note: Per 2 C.F.R. § 25.200, applicants must also provide the applicant’s immediate and highest-level owner, subsidiaries, and predecessors that have been awarded federal contracts or federal financial assistance within the last three years, if applicable.

i.    Additional SAM Reminders

Existing SAM.gov account holders should check their account to make sure it is “ACTIVE.” SAM registration should be completed at the very beginning of the application period and should be renewed annually to avoid being “INACTIVE.” Please allow plenty of time before the grant application submission deadline to obtain an UEI number and then to register in SAM. It may be four weeks or more after an applicant submits the SAM registration before the registration is active in SAM, and then it may be an additional 24 hours before FEMA’s system recognizes the information.

It is imperative that the information applicants provide is correct and current. Please ensure that your organization’s name, address, and EIN are up to date in SAM and that the UEI number used in SAM is the same one used to apply for all other FEMA awards. Payment under any FEMA award is contingent on the recipient’s having a current SAM registration.

ii.   Help with SAM

The SAM quick start guide for new recipient registration and SAM video tutorial for new applicants are tools created by the General Services Administration (GSA) to assist those registering with SAM. If applicants have questions or concerns about a SAM registration, please contact the Federal Support Desk at https://www.fsd.gov/fsd-gov/home.do or call toll free (866) 606-8220.

f.    Register in FEMA GO, Add the Organization to the System, and Establish the AOR: 

Applicants must register in FEMA GO and add their organization to the system. The organization’s electronic business point of contact (EBiz POC) from the SAM registration may need to be involved in this step. For step-by-step instructions, see https://www.fema.gov/grants/guidance-tools/fema-go/startup.

Note: FEMA GO will support only the most recent major release of the following browsers:

• ·          Google Chrome
• ·          Internet Explorer
• ·          Mozilla Firefox
• ·          Apple Safari
• ·          Microsoft Edge

Users who attempt to use tablet type devices or other browsers may encounter issues with using FEMA GO.

8.   Submitting the Application

Applicants (SAAs) will be prompted to submit the standard application information and any program-specific information required as described in Section D.10 of this NOFO, “Content and Form of Application Submission.” The Standard Forms (SF) may be accessed in the Forms tab under the https://grants.gov/forms/forms-repository/sf-424-family. Applicants should review these forms before applying to ensure they have all the information required.

After submitting the final application, FEMA GO will provide either an error message or a successfully received transmission in the form of an email sent to the AOR that submitted the application. Applicants using slow internet connections, such as dial-up connections, should be aware that transmission can take some time before FEMA GO receives your application.

For additional application submission requirements, including program-specific requirements, please refer to the subsection titled “Content and Form of Application Submission” under Section D of this NOFO.

9.   Timely Receipt Requirements and Proof of Timely Submission

All applications must be completed in FEMA GO by the application deadline. FEMA GO automatically records proof of timely submission and the system generates an electronic date/time stamp when FEMA GO successfully receives the application. The individual with the AOR role that submitted the application will also receive the official date/time stamp and a FEMA GO tracking number in an email serving as proof of their timely submission on the date and time that FEMA GO received the application.

Applicants who experience system-related issues will be addressed until 3:00 PM ET on the date applications are due. No new system-related issues will be addressed after this deadline. Applications not received by the application submission deadline will not be accepted.

10.      Content and Form of Application Submission

a.   Standard Required Application Forms and Information

Generally, applicants have to submit either the non-construction forms (i.e., SF-424A and SF-424B) or construction forms (i.e., SF-424C and SF-424D), meaning that applicants that only have construction work and do not have any non-construction work need only submit the construction forms (i.e., SF-424C and SF-424D) and not the non-construction forms (i.e., SF-424A and SF-424B), and vice versa. However, applicants who have both construction and non-construction work under this program need to submit both the construction and non-construction forms. 

The following forms or information are required to be submitted via FEMA GO. The Standard Forms (SF) are also available at https://grants.gov/forms/forms-repository/sf-424-family. 

• SF-424, Application for Federal Assistance
• Grants.gov Lobbying Form, Certification Regarding Lobbying
• SF-424A, Budget Information (Non-Construction)
  • For construction under an award, submit SF-424C, Budget Information (Construction), in addition to or instead of SF-424A.
  • To comply with 2 C.F.R. § 200.402 - 2 C.F.R. § 200.405, NSGP applicants must complete and submit an SF-424A or SF-424C, as appropriate, reflecting cost breakdown per budget cost categories per sub-programs (NSGP-S and NSGP-UA) and Management and Administration costs as applicable to align with the FY 2024 NSGP funding notice. The SF-424A or SF-424C with the pre-filled requirements can be found with the NSGP funding notice and associated attachments on grants.gov. Adjustments to the SF-424A or SF-424C maybe required after the FY 2024 NSGP final allocation announcements are made. GPD Grants Management Specialists will contact applicants for any necessary revisions. 
• SF-424B, Standard Assurances (Non-Construction)
  • For construction under an award, submit SF-424D, Standard Assurances (Construction), in addition to or instead of SF-424B
• SF-LLL, Disclosure of Lobbying Activities

b.   Program-Specific Required Forms and Information

The following program-specific forms or information are required to be submitted in FEMA GO: 

• Investment Justifications (IJ) from ALL nonprofit subapplicants, regardless of if the SAA recommends them for funding in the provided FY 2024 IJ Template (OMB Control Number: 1660-0110/FEMA Form FF-207-FY-21-115). 
• SAA Prioritization of IJs in the DHS/FEMA-provided template (OMB Control Number: 1660-0110/FEMA Form FF 207-21-114) located in the Related Documents tab of the Grants.gov posting: 
  • SAAs must submit a Prioritization of IJs for NSGP-UA and a separate Prioritization of IJs for NSGP-S. 
  • SAAs must include nonprofit organization application details (e.g., nonprofit organization name, IJ title(s), requested amount(s)) for each nonprofit organization that applied to the SAA for funding on the State Prioritization of IJs even if not being recommended by the SAA for funding. 
    • IJs for applications not being recommended for funding must still be submitted to FEMA. 
• Each nonprofit organization being recommended for funding must be scored and must have a unique rank (#1 [one] being the highest ranked through the total number of applications the SAA scored). 
• States with multiple FY 2024 UASI-designated high-risk urban areas must ensure that nonprofits are ranked by high-risk urban area. For example, if a state has three high-risk urban areas, there should be three groups of rankings. 

As part of the FY 2024 NSGP application, each eligible nonprofit subapplicant must submit the following three documents to the SAA by the deadline established by the SAA:

i.    NSGP IJ

Nonprofit subapplicants with one site may apply for up to $150,000 for that site. Nonprofit subapplicants with multiple sites may apply for up to $150,000 per site, for up to three sites per funding stream for a maximum of $450,000 per state. See Section B.3 for more information about this maximum. If a nonprofit subapplicant applies for multiple sites, it must submit one complete IJ per each site. [2] IJs cannot include more than one physical site. 

A fillable IJ form (DHS/FEMA Form FF-207-FY-21-115, OMB Control Number: 1660-0110) is available in the Related Documents tab of the Grants.gov NSGP posting. The IJ must describe each investment proposed for funding. The investments or projects described in the IJ must:

1. Be for the location(s)/physical address(es) (NOT P.O. Boxes) that the nonprofit occupies at the time of application;
2. Address an identified risk, including threat and vulnerability, regardless of whether it is submitting for similar projects at multiple sites;
3. Demonstrate the ability to provide enhancements consistent with the purpose of the program and guidance provided by DHS/FEMA;
4. Be both feasible and effective at reducing the risks for which the project was designed;
5. Be able to be fully completed within the three-year period of performance; and
6. Be consistent with all applicable requirements outlined in this NOFO and the Preparedness Grants Manual.

More information about the IJ’s content and scoring is listed in Appendix A.

Nonprofit subapplicants are required to self-identify with one of the following categories in the IJ as part of the application process: 

1. Ideology-based/Spiritual/Religious
2. Educational
3. Medical
4. Other

ii.   Vulnerability/Risk Assessment 

Each nonprofit subapplicant must include a vulnerability/risk assessment unique to the site the IJ is being submitted for.

iii. Mission Statement

Each nonprofit subapplicant must include its Mission Statement and any mission implementation policies or practices that may elevate the organization’s risk. SAAs will use the Mission Statement along with the nonprofit subapplicant’s self-identification in the IJ to validate that the organization is one of the following types: 1) Ideology-based/Spiritual/Religious; 2) Educational; 3) Medical; or 4) Other. The organization type is a factor when calculating the final score of the application; see Section E “Application Review Information,” subsection “Final Score.”

The Vulnerability/Risk Assessment and Mission Statement are not to be submitted in FEMA GO but should be maintained by the SAA and must be made available to DHS/FEMA upon request.

11. Intergovernmental Review

An intergovernmental review may be required. Applicants must contact their state’s Single Point of Contact (SPOC) to comply with the state’s process under Executive Order 12372

(See https://www.archives.gov/federal-register/codification/executive-order/12372.html; Intergovernmental Review (SPOC List) (whitehouse.gov)

12. Funding Restrictions and Allowable Costs

All costs charged to awards covered by this NOFO must comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200, unless otherwise indicated in the NOFO, the terms and conditions of the award, or the Preparedness Grants Manual. This includes, among other requirements, that costs must be incurred, and products and services must be delivered, within the period of performance of the award. See 2 C.F.R. § 200.403(h) (referring to budget periods, which for FEMA awards under this program is the same as the period of performance).

Federal funds made available through this award may be used for the purpose set forth in this NOFO, the Preparedness Grants Manual, and the terms and conditions of the award and must be consistent with the statutory authority for the award. Award funds may not be used for matching funds for any other federal awards, lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the Federal Government or any other government entity. See the Preparedness Grants Manual for more information on funding restrictions and allowable costs.

a. Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services 

See the Preparedness Grants Manual for information on prohibitions on expending FEMA award funds for covered telecommunications equipment or services.

b. Pre-Award Costs

Recipient (SAA) pre-award costs are allowable only with the prior written approval of DHS/FEMA and as included in the award agreement. To request pre-award costs, a written request must be included with the application, signed by the SAA. The letter must outline what the pre-award costs are for, including a detailed budget break-out of pre-award costs from the post-award costs, and a justification for approval. Subrecipients cannot claim pre-award costs. Please contact your SAA should exigent circumstances exist. 

c. Management and Administration (M&A) Costs

M&A costs are allowed by the 2024 DHS Appropriations Act. M&A costs are for activities directly related to the management and administration of the award. M&A activities are those defined as directly relating to the management and administration of NSGP funds, such as financial management and monitoring. 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 costs for the NSGP are calculated as up to 5% of the total Federal award allocated to the recipient, not on final expenditures at close out. 

M&A costs are not operational costs but are necessary costs incurred in direct support of the federal award or as a consequence of it, such as travel, meeting-related expenses, and salaries of full/part-time staff in direct support of the program. As such, M&A costs can be itemized in financial reports. Other M&A costs examples include preparing and submitting required programmatic and financial reports, establishing and/or maintaining equipment inventory, documenting operational and equipment expenditures for financial accounting purposes, and responding to official informational requests from state and federal oversight authorities.

Note: SAAs must be able to separately account for M&A costs associated with the NSGP-UA award from those associated with the NSGP-S award.

M&A costs are allowed under this program as described below:

i.    SAA (Recipient) for NSGP-S and NSGP-UA M&A

The SAA may use and expend up to 5% of their total FY 2024 NSGP-S and NSGP-UA awards for M&A purposes associated with administering the NSGP-S and NSGP-UA awards. SAAs must include the amount they are requesting for NSGP-S and NSGP-UA M&A in the SF-424A form. The amount should be in addition to the total requested by the subapplicant nonprofit organizations, but not exceed 5% of the total requested by the subapplicant nonprofit organizations.  SAAs must be able to separately account for M&A costs associated with the NSGP-UA award from those associated with the NSGP-S.

ii.   Nonprofit Organization (subrecipient) for NSGP-S and NSGP-UA M&A

Nonprofit organizations that receive a subaward under the NSGP may use and expend up to 5% of each subaward for M&A purposes associated with that subaward. If an organization is receiving more than one subaward, they must be able to separately account for M&A costs for each subaward.

d.   Indirect Facilities & Administrative (F&A) Costs

Indirect (F&A) costs (IDC) mean those costs incurred for a common or joint purpose benefitting more than one cost objective and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. IDC are allowable by the recipient [and subrecipients] as described in 2 C.F.R. Part 200, including 2 C.F.R. § 200.414. Applicants with a current negotiated IDC rate agreement who desire to charge indirect costs to a federal award must provide a copy of their IDC rate agreement with their applications. Not all applicants are required to have a current negotiated IDC rate agreement. Applicants that are not required to have a negotiated IDC rate agreement but are required to develop an IDC rate proposal must provide a copy of their proposal with their applications. Applicants who do not have a current negotiated IDC rate agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to FEMA for further instructions. Applicants who wish to use a cost allocation plan in lieu of an IDC rate proposal must reach out to the FEMA Point of Contact for further instructions. As it relates to the IDC for subrecipients, a recipient must follow the requirements of 2 C.F.R. §§ 200.332 and 200.414 in approving the IDC rate for subawards. For information on procedures for establishing indirect cost rates, see the Preparedness Grants Manual.

d. Evaluation Costs

Per Section H.2 of this NOFO, specific evaluation costs associated with the award or subaward may be allowable. See Section H.2 “Program Evaluation” for more details. 

f.    Other Direct Costs

i.    Planning

Planning costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual.

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 as well as those with limited English proficiency. Planning efforts can also include conducting risk and resilience assessments on increasingly connected cyber and physical systems, on which security depends, using the Resilience Planning Program | CISA and related CISA resources. Examples of planning activities allowable under this program include: 

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

ii.   Organization 

Organization costs are not allowed under this program. 

iii.  Equipment

Equipment costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual. 

Allowable costs are focused on facility 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 or other extremist attack. This equipment is limited to select items on the Authorized Equipment List (AEL). These items, including the item’s plain-language description specific to the NSGP, are as follows: 

Other dropdowns in the Section IV-B of IJ, while not part of the AEL, include the following:

Unless otherwise stated, equipment must meet all mandatory statutory, regulatory, and FEMA-adopted standards to be eligible for purchase using these funds, including the Americans with Disabilities Act. In addition, recipients will be responsible for obtaining and maintaining all necessary certifications and licenses for the requested equipment, whether with NSGP funding or other sources of funds (see the Maintenance and Sustainment section below for more information). 

Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior approval from FEMA. Note: Nonprofits should indicate in their budget narratives if a cost includes shipping and/or tax. It is not required to break the costs out as separate from the relevant purchase(s).

Applicants and subapplicants should analyze the cost benefits of purchasing versus leasing equipment, especially high-cost items and those subject to rapid technical advances. Large equipment purchases must be identified and explained. For more information regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including but not limited to 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1 – Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or ServicesFEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, regarding prohibitions on covered telecommunications equipment or services. Additionally, recipients that are using NSGP funds to support emergency communications equipment activities must comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance can be found at the Funding and Sustainment page on CISA.govFunding Resources | CISA.

The Installation of certain equipment may trigger Environmental Planning and Historic Preservation (EHP) requirements. Please reference the EHP sections in this NOFO and the Preparedness Grants Manual for more information. Additionally, some equipment installation may constitute construction or renovation. Please see the Construction and Renovation subsection for additional information.

iv.  Training and Exercises

Training and exercise costs are allowed under this program only as described in this funding notice and the Preparedness Grants Manual.  

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

1. Employed or volunteer security staff to attend security-related training within the United States;
2. 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
3. Nonprofit organization’s employees, or members/congregants to receive on-site security training. 

Allowable training-related costs under the NSGP are limited to attendance fees for training and related expenses, such as materials, supplies, and/or equipment. Overtime, backfill, and travel expenses are not allowable costs. 

Allowable training topics are limited to the protection of critical infrastructure key resources, including physical and cybersecurity, facility hardening, and terrorism/other extremism awareness/employee preparedness such as Community Emergency Response Team (CERT) training, indicators and behaviors indicative of terrorist/other extremist threats, Active Shooter training, and emergency first aid training. Additional examples of allowable training courses include: “Stop the Bleed” training, kits/equipment, and training aids; First Aid and other novice level “you are the help until help arrives” training, kits/equipment, and training aids; and Automatic External Defibrillator (AED) and AED/Basic Life Support training, kits/equipment, and training aids. 

Training conducted using NSGP funds must address a specific threat and/or vulnerability, as identified in the nonprofit organization’s Investment Justification (IJ). Training should provide the opportunity to demonstrate and validate skills learned as well as to identify any gaps in these skills. Proposed attendance at training courses and all associated costs using the NSGP must be included in the nonprofit organization’s IJ.

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, and 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. All shortcomings or gaps—including those identified for children and individuals with access and functional needs—should be identified in an improvement plan. Improvement plans should be dynamic documents with corrective actions continually monitored and implemented as part of improving preparedness through the exercise cycle. 

The Homeland Security Exercise and Evaluation Program (HSEEP) provides a set of guiding principles for exercise programs, as well as a common approach to exercise program management, design and development, conduct, evaluation, and improvement planning. For additional information on HSEEP, refer to Homeland Security Exercise and Evaluation Program | FEMA.gov. In accordance with HSEEP guidance, subrecipients are reminded of the importance of implementing corrective actions iteratively throughout the progressive exercise cycle. This link provides access to a sample After Action Report (AAR)/Improvement Plan (IP) template: Improvement Planning – HSEEP Resources – Preparedness Toolkit (fema.gov). Recipients are encouraged to enter their exercise data and AAR/IP in the Preparedness Toolkit.

v.   Maintenance and Sustainment

Maintenance and sustainment costs, such as maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable. For additional information, see the Preparedness Grants Manual.

vi.  Construction and Renovation

NSGP funding may not be used for construction and renovation projects without prior written approval from FEMA. In some cases, the installation of equipment may constitute construction and/or renovation. If you have any questions regarding whether an equipment installation project could be considered construction or renovation, please contact your Preparedness Officer. All recipients of NSGP funds must request and receive prior approval from FEMA before any NSGP funds are used for any construction or renovation. Additionally, recipients are required to submit a SF-424C Budget and budget detail citing the project costs and an SF-424D Form for standard assurances for the construction project. The total cost of any construction or renovation paid for using NSGP funds may not exceed the greater amount of $1 million or 15% of the NSGP award.  

vii.  Contracted Security Personnel

Contracted security personnel are allowed under this program only as described in this NOFO and must comply with guidance set forth in IB 441. NSGP funds may not be used to purchase equipment for contracted security. 

e. Unallowable Costs

The following projects and costs are considered ineligible for award consideration:

• Organization costs, and operational overtime costs;
• Hiring of public safety personnel;
• General-use expenditures;
• Overtime and backfill; 
• Initiatives that do not address the implementation of programs/initiatives to build prevention and protection-focused capabilities directed at identified facilities and/or the surrounding communities;
• The development of risk/vulnerability assessment models;
• Initiatives that fund risk or vulnerability security assessments or the development of the IJ;
• Initiatives in which federal agencies are the beneficiary or that enhance federal property;
• Initiatives which study technology development;
• Proof-of-concept initiatives;
• Initiatives that duplicate capabilities being provided by the Federal Government;
• Organizational operating expenses;
• Reimbursement of pre-award security expenses (see Section D.12.b);
• Cameras for license plate readers/license plate reader software;
• Cameras for facial recognition software;
• Weapons or weapons-related training; and
• Knox boxes.

E.  Application Review Information

1. Application Evaluation Criteria

a.   Programmatic Criteria

Nonprofit organizations must submit their FY 2024 NSGP applications to their respective SAA by the deadline established by the SAA. If an SAA has established deadline that is prior to release of the FY 2024 NSGP funding notice, the SAA is responsible for working with any nonprofits that may need to amend their submissions to account for changes in the FY 2024 NSGP program prior to the start of the SAA application evaluation process. FY 2024 NSGP-S and NSGP-UA applications will be reviewed through a two-phase state and federal review process for completeness, adherence to programmatic guidelines, feasibility, and how well the IJ (project description and justification) addresses the identified risk(s). For FY 2024 NSGP-S, SAAs will make recommendations to DHS/FEMA based on their target allocation and according to the chart listed in the NSGP-S Process subsection below.

The following are the FY 2024 NSGP-S and NSGP-UA evaluation process and criteria:

• For NSGP-UA, state and federal verification that the nonprofit organization is located within one of the FY 2024 UASI-designated high-risk urban areas (contact the appropriate SAA for the UAWG-defined high-risk urban area footprints); and for NSPG-S, verification that the nonprofit is located outside of one of the FY 2024 UASI-designated high-risk urban areas;
• Identification and substantiation of current or persistent threats or attacks (from within or outside the United States) by a terrorist or other extremist organization, network, or cell against the subapplicant based on their ideology, beliefs, and/or mission as: 1) an ideology-based/spiritual/religious; 2) educational; 3) medical; or 4) other nonprofit entity; 
• Symbolic value of the site(s) as a highly recognized regional and/or national or historical institution(s) that renders the site a possible target of terrorist or other extremist attack;
• Role of the nonprofit organization in responding to or recovering from terrorist or other extremist attacks;
• Alignment between the project activities requested within the physical or cyber vulnerabilities identified in the organization’s vulnerability assessment;
• Integration of nonprofit preparedness with broader state and local preparedness efforts;
• Completed IJ for each site that addresses an identified risk unique to that site, including the assessed threat, vulnerability, and consequence of the risk;
• Demonstration that the nonprofit organization is located within a disadvantaged community; see Section E, Application Review Information – Review and Selection Process, for additional information on how this demonstration will affect scores; and 
• History of prior funding under NSGP. Not having received prior year NSGP funding is a positive factor when calculating the state score of the application; see Section E, Application Review Information – Review and Selection Process, for additional information.

Grant projects must be: 1) both feasible and effective at mitigating the identified vulnerability and thus reducing the risks for which the project was designed; and 2) able to be fully completed within the three-year period of performance. DHS/FEMA will use the information provided in the application, as well as any supporting documentation, to determine the feasibility and effectiveness of the grant project. Information that would assist in the feasibility and effectiveness determination includes the following:

• Scope of work (purpose and objectives of the project, identification of what is being protected);
• Desired outcomes, including expected long-term impact where applicable;
• Summary of status of planning and design accomplished to date (e.g., included in a capital improvement plan); and
• Project schedule.

Recipients and subrecipients are expected to conform, as applicable, with accepted engineering practices, established codes, standards, modeling techniques, and best practices.

b.   Financial Integrity Criteria

Prior to making a federal award, FEMA is required by 31 U.S.C. § 3354, as enacted by the Payment Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313; and 2 C.F.R. § 200.206 to review information available through any Office of Management and Budget (OMB)-designated repositories of governmentwide eligibility qualification or financial integrity information, including whether SAM.gov identifies the applicant as being excluded from receiving federal awards or is flagged for any integrity record submission. FEMA may also pose additional questions to the applicant to aid in conducting the pre-award risk review. Therefore, application evaluation criteria may include the following risk-based considerations of the applicant: 

i.    Financial stability. 

ii.   Quality of management systems and ability to meet management standards.

iii.  History of performance in managing federal award. 

iv.  Reports and findings from audits.

v.   Ability to effectively implement statutory, regulatory, or other requirements.

c.   Supplemental Financial Integrity Criteria and Review

Prior to making a federal award where the anticipated total federal share will be greater than the simplified acquisition threshold, currently $250,000:

i.    FEMA is required by 41 U.S.C. § 2313 and 2 C.F.R. § 200.206(a)(2) to review and consider any information about the applicant, including information on the applicant’s immediate and highest-level owner, subsidiaries, and predecessors, if applicable, that is in the designated integrity and performance system accessible through the System for Award Management (SAM), which is currently the Federal Awardee Performance and Integrity Information System (FAPIIS).

ii.   An applicant, at its option, may review information in FAPIIS and comment on any information about itself that a federal awarding agency previously entered.

iii.  FEMA will consider any comments by the applicant, in addition to the other information in FAPIIS, in making a judgment about the applicant’s integrity, business ethics, and record of performance under federal awards when completing the review of risk posed by applicants as described in 2 C.F.R. § 200.206.

d.  Security Review

DHS Intelligence and Analysis receives a list of potential NSGP subrecipient organizations, which it reviews against U.S. intelligence community reporting. The security review occurs after the competitive scoring and selection process is complete. The information provided for the security review is limited to the nonprofit organization’s name and physical address, as submitted by the nonprofit organization. Any potentially derogatory information, as well as any potentially mitigating information, that could assist in determining whether a security risk exists is sent to FEMA and is used in making final award decisions.

2.   Review and Selection Process

a. NSGP-UA Process

State Review 

Application packages are submitted by the nonprofit organization to the SAA based on the established criteria. As part of the review for NSGP-UA, the SAAs must:

• Conduct an eligibility review, in coordination with the UAWG;
• Verify that the nonprofit is located within a FY 2024 UASI-designated high-risk urban area;
• Review and score only complete application packages (including mission statements and vulnerability assessments) using the NSGP Scoring Criteria provided by DHS/FEMA; 
• Validate the self-certified organization type listed in the IJ by assessing the central purpose of the organization described in the mission statement;
• Prioritize all NSGP IJs by ranking each IJ. Each IJ will receive a unique rank (#1 [one] being the highest ranked through the total number of applications the SAA scored);
• For states with multiple FY 2024 UASI-designated high-risk urban areas, each high-risk urban area must be ranked separately;
• Submit the results of the SAA review of complete applications from eligible subapplicants to DHS/FEMA using the SAA Prioritization Tracker;
• Submit nonprofit organization application details for applications received but not recommended for funding (including incomplete applications and ineligible subapplicants), as well as justification as to why they are not being recommended for funding to DHS/FEMA using the SAA Prioritization Tracker (IJs for applications not being recommended for funding should not be submitted to FEMA);
• Submit IJs that are recommended for funding; 
• Submit IJs received and not recommended for funding, including incomplete IJs and IJs from subapplicants deemed ineligible; and 
• Retain the mission statements and vulnerability assessments submitted by each nonprofit organization.

The SAA will base the ranking on the final scores from the Prioritization Tracker as determined by the SAA’s subject-matter expertise and discretion with consideration of the following factors:

• Need: the relative need for the nonprofit organization compared to the other subapplicants; and
• Impact: the feasibility of the proposed project and how effectively the proposed project addresses the identified need.

The SAA reviewers will score each question in the IJ according to the scoring matrix in Appendix A.

Federal Review

The highest-ranking IJs from each submitting high-risk urban area are reviewed by a panel made up of DHS/FEMA federal staff. As a part of this review, federal staff will also verify that the nonprofit is located within a FY 2024 UASI-designated high-risk urban area. 

Federal reviewers will review each IJ to check for the following:

• Eligibility (e.g., that a potential subrecipient meets all the criteria for the program);
• Allowability of the proposed project(s); and 
• Any derogatory information on the organization applying per Section E.1.d “Security Review.”
  • By a factor of three for ideology-based/spiritual/religious entities;

Final Score

To calculate an application’s final score, the subapplicant’s SAA score will be multiplied:

• By a factor of two for medical and educational institutions; and
• By a factor of one for all other nonprofit organizations.

Subapplicants that have never received an NSGP award will have 15 points added to their score. 

To advance considerations of equity in awarding NSGP grant funding, FEMA will add 10 additional points to the scores of organizations that are located within a disadvantaged community and demonstrate how they serve a disadvantaged community or population. FEMA will apply the Council on Environmental Quality’s Climate and Economic Justice Screening Tool (CEJST)[3] to each subapplicant using the address of their physical location. FEMA will add 10 points to applications from organizations in communities identified as “disadvantaged” by CEJST.

Subapplicants will be selected from highest to lowest scored. In the event of a tie during the funding determination process, priority will be given to nonprofit organizations that are located in disadvantaged communities, then those that have not received prior year funding, and then those prioritized highest by their SAA. Should additional NSGP-UA funding remain unobligated after reviewing all submissions, FEMA will use the final scores, in part, to determine how the remaining balance of funds will be allocated. Submissions will be selected for funding until the remaining balance of funds is exhausted.

DHS/FEMA will use the final results to make funding recommendations to the Secretary of Homeland Security. All final funding determinations will be made by the Secretary of Homeland Security, who retains the discretion to consider other factors and information in addition to DHS/FEMA’s funding recommendations.

b. NSGP-S Process

State Review 

Application packages are submitted by the nonprofit organization to the SAA based on the established criteria. The SAA will review applications and recommend to DHS/FEMA which nonprofit organizations should be selected for funding. As part of the state review, the SAAs must:

• Conduct an eligibility review;
• Verify that the nonprofit is located outside a FY 2024 UASI-designated high-risk urban area;
• Review and score all complete application packages (including vulnerability assessments and mission statement) using the NSGP Scoring Criteria provided by DHS/FEMA; 
• Validate the self-certified organization type listed in the IJ by assessing the central purpose of the organization described in the mission statement;
• Prioritize all NSGP IJs by ranking each IJ. Each IJ will receive a unique rank (#1 [one] being the highest ranked through the total number of applications the SAA scored);
• Submit the results of the state review along with complete investment justifications from eligible subapplicants to DHS/FEMA using the SAA Prioritization Tracker;
• Submit nonprofit organization application details for applications received but not recommended for funding (including incomplete applications and ineligible subapplicants), as well as justification as to why they are not being recommended for funding to DHS/FEMA using the SAA Prioritization Tracker (IJs for applications not being recommended for funding should not be submitted to FEMA);
• Submit IJs that are recommended for funding; SAAs should submit IJs that collectively represent 150% of the state’s NSGP-S allocation; this will allow DHS/FEMA to award the next prioritized IJ in instances when a subapplicant is found to be ineligible or when a significant portion of an IJ includes proposed projects that are unallowable, for example:

• Submit IJs received and not recommended for funding, including incomplete IJs and IJs from subapplicants deemed ineligible. 
• Retain the mission statements and vulnerability assessments submitted by each nonprofit organization.

The SAA will base the ranking on the final scores from the Prioritization Tracker as determined by the SAA’s subject-matter expertise and discretion with consideration of the following factors:

• Need: The relative need for the nonprofit organization compared to the other subapplicants; and
• Impact: The feasibility of the proposed project and how effectively the proposed project addresses the identified need.

The SAA reviewers will score each question in the IJ according to the scoring matrix in Appendix A.

Federal Review

The IJs submitted by each SAA will be reviewed by DHS/FEMA federal staff. Federal staff will also verify that the nonprofit organization is located outside of a FY 2024 UASI-designated high-risk urban area. Federal reviewers will review each IJ to check for the following:

• Eligibility (e.g., that a potential subrecipient meets all the criteria for the program);
• Allowability of the proposed project(s); and 
• Any derogatory information on the organization applying per Section E.1.d “Security Review.”

Final Score

To calculate an application’s final score, the subapplicant's SAA score will be multiplied:

• By a factor of three for nonprofit groups that are at a high risk of terrorist or other extremist attacks due to their ideology, beliefs, or mission;
• By a factor of two for medical and educational institutions; and
• By a factor of one for all other nonprofit organizations.

Subapplicants who have never received a NSGP award will have 15 points added to their score. 

To advance considerations of equity in awarding NSGP grant funding, FEMA will add 10 additional points to the scores of organizations that are located within a disadvantaged community and demonstrate how they serve a disadvantaged community or population. FEMA will apply the Council on Environmental Quality’s Climate and Economic Justice Screening Tool (CEJST)[4] to each subapplicant using the address of their physical location. FEMA will add 10 points to applications from organizations in communities identified as “disadvantaged” by CEJST. 

Subapplicants will be selected from highest to lowest scored within their respective state/territory until the available state target allocation has been exhausted. In the event of a tie during the funding determination process, priority will be given to nonprofit organizations located in disadvantaged communities, then those that have not received prior year funding, and then those prioritized highest by their SAA. Should additional NSGP-S funding remain unobligated after reviewing all state/territory submissions, FEMA will use the final scores, in part, to determine how the remaining balance of funds will be allocated. Submissions will be selected for funding until the remaining balance of funds is exhausted.

DHS/FEMA will use the final results to make funding recommendations to the Secretary of Homeland Security. All final funding determinations will be made by the Secretary of Homeland Security, who retains the discretion to consider other factors and information in addition to DHS/FEMA’s funding recommendations.

F.   Federal Award Administration Information

Notice of Award

Before accepting the award, the AOR and recipient should carefully read the award package. The award package includes instructions on administering the grant award and the terms and conditions associated with responsibilities under federal awards. Recipients must accept all conditions in this NOFO and the Preparedness Grants Manual as well as any specific terms and conditions in the Notice of Award to receive an award under this program.

See the Preparedness Grants Manual for information on Notice of Award.

FEMA will provide the federal award package to the applicant electronically via FEMA GO. Award packages include an Award Letter, Summary Award Memo, Agreement Articles, and Obligating Document. An email notification of the award package will be sent through FEMA’s grant application system to the AOR that submitted the application. 

Recipients (SAA) must accept their awards no later than 60 days from the award date. The recipient shall notify FEMA of its intent to accept and proceed with work under the award through the FEMA GO system. 

Funds will remain on hold until the recipient accepts the award through the FEMA GO system and all other conditions of the award have been satisfied or until the award is otherwise rescinded. Failure to accept a grant award within the specified timeframe may result in a loss of funds.

2.   Pass-Through Requirements

Pass-through funding is required under this program. For more information, please see the Preparedness Grants Manual.

3.   Required Notice of Non-Selection

Starting in FY 2024, SAAs are required to inform nonprofit organization subapplicants of their non-selection. FEMA will provide an optional template that SAAs can use; however, SAAs can modify this template as needed. SAAs are required to inform subapplicants of their non-selection no later than 90 days from the date they accept their NSGP award (see Section F.1). 

4.   Administrative and National Policy Requirements

In addition to the requirements of in this section and in this NOFO, FEMA may place specific terms and conditions on individual awards in accordance with 2 C.F.R. Part 200.

In addition to the information regarding DHS Standard Terms and Conditions and Ensuring the Protection of Civil Rights, see the Preparedness Grants Manual for additional information on administrative and national policy requirements, including the following:

• ·    Environmental Planning and Historic Preservation (EHP) Compliance
• ·    FirstNet
• ·    National Incident Management System (NIMS) Implementation
• ·    SAFECOM

a.   DHS Standard Terms and Conditions

All successful applicants for DHS grant and cooperative agreements are required to comply with DHS Standard Terms and Conditions, which are available online at: DHS Standard Terms and Conditions.

The applicable DHS Standard Terms and Conditions will be those in effect at the time the award was made. What terms and conditions will apply for the award will be clearly stated in the award package at the time of award.

b.   Ensuring the Protection of Civil Rights

As the Nation works towards achieving the National Preparedness Goal, it is important to continue to protect the civil rights of individuals. Recipients and subrecipients must carry out their programs and activities, including those related to the building, sustainment, and delivery of core capabilities, in a manner that respects and ensures the protection of civil rights for protected populations. 

Federal civil rights statutes, such as Section 504 of the Rehabilitation Act of 1973 and Title VI of the Civil Rights Act of 1964, along with 

DHS and FEMA regulations, prohibit discrimination on the basis of race, color, national origin, sex, religion, age, disability, limited English proficiency, or economic status in connection with programs and activities receiving federal financial assistance from FEMA, as applicable. 

The DHS Standard Terms and Conditions include a fuller list of the civil rights provisions that apply to recipients. These terms and conditions can be found in the DHS Standard Terms and Conditions. Additional information on civil rights provisions is available at https://www.fema.gov/about/offices/equal-rights/civil-rights.

Monitoring and oversight requirements in connection with recipient compliance with federal civil rights laws are also authorized pursuant to 44 C.F.R. Part 7 or other applicable regulations.

In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment.

c.  Environmental Planning and Historic Preservation (EHP) Compliance

See the Preparedness Grants Manual for information on EHP compliance.

d. National Incident Management System (NIMS) Implementation

In expending funds under this program, recipients that are state, local, tribal, or territorial governments must ensure and maintain adoption and implementation of NIMS. The state, local, tribal, or territorial government must show adoption of NIMS during any point of the period of performance. See the Preparedness Grants Manual for information about NIMS implementation. 

e.  Mandatory Disclosures

The non-Federal entity or applicant for a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. (2 C.F.R. § 200.113)

Please note applicants and recipients may report issues of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323-8603, and TTY 1 (844) 889-4357.

5.   Reporting

Recipients are required to submit various financial and programmatic reports as a condition of award acceptance. Future awards and funds drawdown may be withheld if these reports are delinquent. 

See the Preparedness Grants Manual for information on reporting requirements.

6.   Monitoring and Oversight

The regulation at 2 C.F.R. § 200.337 provides DHS and any of its authorized representatives with the right of access to any documents, papers, or other records of the recipient [and any subrecipients] that are pertinent to a federal award in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the recipient’s or subrecipient’s personnel for the purpose of interview and discussion related to such documents. Pursuant to this right and per 2 C.F.R. § 200.329, DHS may conduct desk reviews and make site visits to review project accomplishments and management control systems to evaluate project accomplishments and to provide any required technical assistance. During site visits, DHS may review a recipient’s or subrecipient’s files pertinent to the federal award and interview and/or discuss these files with the recipient’s or subrecipient’s personnel. Recipients and subrecipients must respond in a timely and accurate manner to DHS requests for information relating to a federal award.

See the Preparedness Grants Manual for information on monitoring and oversight.

G.  DHS Awarding Agency Contact Information

Contact and Resource Information

a.   Program Office Contact

FEMA has assigned state-specific Preparedness Officers for the NSGP. If you do not know your Preparedness Officer, please contact FEMA Grants News by e-mail at fema-grants-news@fema.dhs.gov OR by phone at (800) 368-6498, Monday through Friday, 9:00 AM – 5:00 PM ET.

b.   FEMA Grants News

FEMA Grants News is a non-emergency comprehensive management and information resource developed by FEMA for grants stakeholders. This channel provides general information on all FEMA grant programs and maintains a comprehensive database containing key personnel contact information at the federal, state, and local levels. When necessary, recipients will be directed to a federal point of contact who can answer specific programmatic questions or concerns. FEMA Grants News can be reached by e-mail at fema-grants-news@fema.dhs.gov OR by phone at (800) 368-6498, Monday through Friday, 9:00 AM – 5:00 PM ET.

c.   Grant Programs Directorate (GPD) Award Administration Division

GPD’s Award Administration Division (AAD) provides support regarding financial matters and budgetary technical assistance. Additional guidance and information can be obtained by contacting the AAD’s Help Desk via e-mail at ASK-GMD@fema.dhs.gov.

d.   FEMA Regional Offices 

FEMA Regional Offices also may provide fiscal support, including pre- and post-award administration and technical assistance such as conducting cash analysis, financial monitoring, and audit resolution to the grant program under this NOFO. GPD will provide programmatic support and technical assistance.

FEMA Regional Office contact information is available at https://www.fema.gov/fema-regional-contacts.

e.   Equal Rights

The FEMA Office of Equal Rights (OER) is responsible for compliance with and enforcement of federal civil rights obligations in connection with programs and services conducted by FEMA and recipients of FEMA financial assistance. All inquiries and communications about federal civil rights compliance for FEMA grants under this NOFO should be sent to FEMA-CivilRightsOffice@fema.dhs.gov.

f.    Environmental Planning and Historic Preservation

GPD’s EHP Team provides guidance and information about the EHP review process to recipients and subrecipients. All inquiries and communications about GPD projects under this NOFO or the EHP review process, including the submittal of EHP review materials, should be sent to gpdehpinfo@fema.dhs.gov.

2.   Systems Information

a.   FEMA GO

For technical assistance with the FEMA GO system, please contact the FEMA GO Helpdesk at femago@fema.dhs.gov or (877) 585-3242, Monday through Friday, 9:00 AM – 6:00 PM ET.

H.  Additional Information

GPD has developed the Preparedness Grants Manual to guide applicants and recipients of grant funding on how to manage their grants and other resources. Recipients seeking guidance on policies and procedures for managing preparedness grants should reference the Preparedness Grants Manual for further information. Examples of information contained in the Preparedness Grants Manual include:

• ·    Actions to Address Noncompliance
• ·    Audits
• ·    Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations
• ·    Community Lifelines
• ·    Conflicts of Interest in the Administration of Federal Awards and Subawards
• ·    Disability Integration
• ·    National Incident Management System
• ·    Payment Information
• ·    Period of Performance Extensions
• ·    Procurement Integrity
• ·    Record Retention
• ·    Whole Community Preparedness
• ·    Report issues of Fraud, Waste, and Abuse 
• ·    Hazard Resistant Building Codes
• ·    Other Post-Award Requirements

1. Termination Provisions

FEMA may terminate a federal award in whole or in part for one of the following reasons. FEMA and the recipient must still comply with closeout requirements at 2 C.F.R. §§ 200.344-200.345 even if an award is terminated in whole or in part. To the extent that subawards are permitted under this NOFO, pass-through entities should refer to 2 C.F.R. § 200.340 for additional information on termination regarding subawards. Note that all information in this Section H.1 “Termination Provisions” is repeated in the Preparedness Grants Manual.

a.   Noncompliance

If a recipient fails to comply with the terms and conditions of a federal award, FEMA may terminate the award in whole or in part. If the noncompliance can be corrected, FEMA may first attempt to direct the recipient to correct the noncompliance. This may take the form of a Compliance Notification. If the noncompliance cannot be corrected or the recipient is non-responsive, FEMA may proceed with a Remedy Notification, which could impose a remedy for noncompliance per 2 C.F.R. § 200.339, including termination. Any action to terminate based on noncompliance will follow the requirements of 2 C.F.R. §§ 200.341-200.342 as well as the requirement of 2 C.F.R. § 200.340(c) to report in FAPIIS the recipient’s material failure to comply with the award terms and conditions. See also the section on Actions to Address Noncompliance in the PreparednessGrants Manual.

b.   With the Consent of the Recipient

FEMA may also terminate an award in whole or in part with the consent of the recipient, in which case the parties must agree upon the termination conditions, including the effective date, and in the case of partial termination, the portion to be terminated. 

c.   Notification by the Recipient

The recipient may terminate the award, in whole or in part, by sending written notification to FEMA setting forth the reasons for such termination, the effective date, and in the case of partial termination, the portion to be terminated. In the case of partial termination, FEMA may determine that a partially terminated award will not accomplish the purpose of the federal award, so FEMA may terminate the award in its entirety. If that occurs, FEMA will follow the requirements of 2 C.F.R. §§ 200.341-200.342 in deciding to fully terminate the award. 

2.  Program Evaluation

Federal agencies are required to structure NOFOs that incorporate program evaluation activities from the outset of their program design and implementation to meaningfully document and measure their progress towards meeting agency priority goal(s) and program outcomes.

OMB Memorandum M-21-27, Evidence-Based Policymaking: Learning Agendas and Annual Evaluation Plans, implementing Title I of the Foundations for Evidence-Based Policymaking Act of 2018, Pub. L. No. 115-435 (2019) (Evidence Act), urges federal awarding agencies to use program evaluation as a critical tool to learn, improve equitable delivery, and elevate program service and delivery across the program lifecycle. Evaluation means “an assessment using systematic data collection and analysis of one or more programs, policies, and organizations intended to assess their effectiveness and efficiency.” Evidence Act, § 101 (codified at 5 U.S.C. § 311). 

As such, recipients and subrecipients are required to participate in a DHS-, Component, or Program Office-led evaluation if selected, which may be carried out by a third-party on behalf of the DHS, its component agencies, or the Program Office. Such an evaluation may involve information collections including but not limited to surveys, interviews, or discussions with individuals who benefit from the federal award program operating personnel, and award recipients, as specified in a DHS-, component agency-, or Program Office-approved evaluation plan. More details about evaluation requirements may be provided in the federal award, if available at that time, or following the award as evaluation requirements are finalized. Evaluation costs incurred during the period of performance are allowable costs (either as direct or indirect). Recipients and subrecipients are also encouraged, but not required, to participate in any additional evaluations after the period of performance ends, although any costs incurred to participate in such evaluations are not allowable and may not be charged to the federal award.

3.   Financial Assistance Programs for Infrastructure

a.   Build America, Buy America Act

Recipients and subrecipients must comply with the Build America, Buy America Act (BABAA), which was enacted as part of the Infrastructure Investment and Jobs Act §§ 70901-70927, Pub. L. No. 117-58 (2021); and Executive Order 14005, Ensuring the Future is Made in All of America by All of America’s Workers. See also 2 C.F.R. Part 184 and Office of Management and Budget (OMB) Memorandum M-24-02, Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure.

None of the funds provided under this program may be used for a project for infrastructure unless the iron and steel, manufactured products, and construction materials used in that infrastructure are produced in the United States.

The Buy America preference only applies to articles, materials, and supplies that are consumed in, incorporated into, or affixed to an infrastructure project. As such, it does not apply to tools, equipment, and supplies, such as temporary scaffolding, brought to the construction site and removed at or before the completion of the infrastructure project. Nor does a Buy America preference apply to equipment and furnishings, such as movable chairs, desks, and portable computer equipment, that are used at or within the finished infrastructure project but are not an integral part of the structure or permanently affixed to the infrastructure project.

For FEMA's official policy on BABAA, please see FEMA Policy 207-22-0001: Buy America Preference in FEMA Financial Assistance Programs for Infrastructure available at https://www.fema.gov/sites/default/files/documents/fema_build-america-buy-america-act-policy.pdf  To see whether a particular FEMA federal financial assistance program is considered an infrastructure program and thus required to include a Buy America preference, please see Programs and Definitions: Build America, Buy America Act | FEMA.gov. and https://www.fema.gov/sites/default/files/documents/fema_build-america-buy-america-act-policy.pdf

b.   Waivers

When necessary, recipients (and subrecipients through their pass-through entity) may apply for, and FEMA may grant, a waiver from these requirements. 

A waiver of the domestic content procurement preference may be granted by the agency awarding official if FEMA determines that:

• Applying the domestic content procurement preference would be inconsistent with the public interest.
• The types of iron, steel, manufactured products, or construction materials are not produced in the United States in sufficient and reasonably available quantities or of a satisfactory quality.
• The inclusion of iron, steel, manufactured products, or construction materials produced in the United States will increase the cost of the overall project by more than 25%.

For FEMA awards, the process for requesting a waiver from the Buy America preference requirements can be found on FEMA’s website at: "Buy America" Preference in FEMA Financial Assistance Programs for Infrastructure | FEMA.gov.

c. Definitions

For BABAA specific definitions, please refer to the FEMA Buy America website at: “Programs and Definitions: Build America, Buy America Act | FEMA.gov.”

Please refer to the applicable DHS Standard Terms & Conditions for the BABAA specific term applicable to all FEMA financial assistance awards for infrastructure.

4.   Report issues of fraud, waste, abuse

Please note, when applying to this notice of funding opportunity and when administering the grant, applicants may report issues of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323-8603, and TTY 1 (844) 889-4357.

5. Protecting Houses of Worship and Public Venues

Across the United States, Americans congregate in faith-based venues to worship, learn, play, and bond as a community. However, public gatherings are vulnerable, and adversaries may perceive houses of worship as attractive targets where they can inflict mass casualties, cause substantial psychological impacts, and draw extensive media coverage. The DHS Center for Faith-Based & Neighborhood Partnerships (DHS Center) partners with interagency and whole community partners to offer numerous resources to assist faith-based and community organizations with their efforts to prepare for all types of hazards, whether natural or man-made. Technical assistance is provided through presentations, workshops, training, webinars, tabletop exercises, and training. Access to these free resources can be found at DHS Center for Faith-Based and Neighborhood Partnerships Resources | FEMA.gov.

Appendix A: Evaluation Criteria and Scoring

View PDF of Appendix A.