Dear Nonprofit Security Friends,

While recent news reporting has raised awareness of Jewish communal concerns about the new so called ”anti-discrimination conditions” to accepting Nonprofit Security Grant Program awards, I can share that these concerns are also being raised within the Catholic and other faith-based communities as well.

Catholic churches and schools, like many other communities of faith, have in increasing numbers sought to participate in the NSGP program. Like many organizations affiliated with the Jewish faith, Catholic and other organizations that are civically engaged, and whose missions are to minister to or serve those most vulnerable and in need in the community, are concerned they will be punished or compromised if found in violation of new presidential executive orders/grant guidance and conditions to i) operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws; ii) engage in a discriminatory prohibited boycott; or iii) operate any program that benefits illegal immigrants or incentivizes illegal immigration.

These conditions are broadly written and, as they are provided without context or illustration, they leave their meaning and scope open to interpretation.

The uncertainty surrounding the impact of these conditions on the mission, programs, and services of potential NSGP applicants, or possible requirements of governmental engagement or interference with their ideology or beliefs as a requisite to receiving the NSGP grant support, could prove anathema to them.

What is being expressed is quickly creating a classic “chilling effect,” which is to say, groups are or will refrain from engaging in applying for the NSGP grant for fear of running afoul of the new conditions.

These concerns coincide with an even greater and broader expression of concern within the professional ranks of the Federal Emergency Management Agency (FEMA) towards the Administration’s overall handling of FEMA as a whole.

Groups that rely on NSGP MUST also pay close attention to these bigger topics that transcend concerns about the impacts of the non-discrimination conditions on award-recipients.

On August 25, 2025, nearly 200 FEMA employees wrote a petition “to warn Congress and the American people of the cascading effects of decisions made by the current administration.” They expressed their opposition to a number of official acts and omissions (processes and leadership deficiencies) that are eroding FEMA’s capacity to ensure effective emergency management. (I think of the delays and murkiness surrounding the 2024 and 2025 NSGP programs awarded and pending.)

They wrote that by drafting this petition they hoped to raise awareness that would “prevent not only another national catastrophe like Hurricane Katrina, but the effective dissolution of FEMA itself and the abandonment of the American people such an event would represent.”

Among their several enumerated concerns, they conveyed their opposition to the interference that has occurred with respect to the preparedness programs (such as NSGP) that build capacity for state and local partners – and are “necessary to respond to a natural disaster, act of terrorism, or other man-made disaster.”

The letter comes after months of upheaval at FEMA, where one-third of the agency’s full-time workforce has left or been fired, including many high-level staff (and those who administer the NSGP program). FEMA, instead, has been led by a series of interim administrators with no prior emergency management experience. Cameron Hamilton, the one acting Administrator who testified before Congress in May to his personal support for not eliminating FEMA, was summarily fired.

The majority of the signatories to the petition signed anonymously for fear of retribution, but those who signed their names have been reported to have been immediately placed on administrative leave for signing the letter.

As I was drafting this blog, the horrific attack occurred at Annunciation Catholic Church in Minneapolis during a children’s Mass. I have a college friend who attended this school, and whose nephew was in one of the church pews during yesterday’s shooting — thankfully physically unhurt, but far from unscathed.

As has been reported by the ADL, the alleged shooter used several firearms that were inscribed with “antisemitic and anti-Israel references; praise for mass killers across the ideological spectrum, including white supremacist, anti-Muslim and anti-government extremists; as well as other school shooters.” Among other evidence of the alleged shooter’s extremism, was writing on the guns that included the name of Natalie Rupnow, who killed two students in December at the Abundant Life Christian School in Madison, WI.

The Annunciation Catholic Church has a website that speaks to its compassion for social justice and its call to take action on issues in its local and wider community. It speaks to its support for a sister school in Leogane, Haiti, which it helps to provide education, elder care, and sustainable farming. I wonder if these programs, activities, and relationships would be disqualifying factors under the program’s new conditions, if Annunciation Catholic Church were to apply for the NSGP program?

In the wake of yesterday’s attack, House Homeland Security Committee Chairman Andrew Garbarino (R-NY) issued a statement on the shooting, in which he said, in part, we must hold this evil to account by ensuring all levels of law enforcement and government can work together to prevent further violence against faith-based communities across our country.”

The Chairman did not speak to NSGP specifically. However, in a meeting I helped plan that took place last week with the Chairman, a client of mine that is a key NSGP stakeholder, delivered a multi-pronged message of concern about NSGP funding levels, delays and departures in NSGP grant awards and NOFO starts, and the potential chilling effect over the new anti-discrimination prohibitions.

The Chairman, who has positively supported funding and improvements to NSGP over the years, although not a “champion” of the program per se, did offer his commitment to investigating the issues that were raised in the meeting. This was a very timely and necessary outreach to the Chairman, and one that will be followed up with further staff engagement and ongoing relationship building and communication.

Let’s make Chairman Garbarino an NSGP champion!

The greater nonprofit sector and faith-based communities need to make their own outreach and engagement with key decision makers in Congress to bolster and protect the Nonprofit Security Grant Program at a time of elevated risk, devastating incidents, and profound disruption and interference with NSGP program norms and practices. If FEMA is allowed to be disbanded and its programs and staff to be further eroded, we run the very real risk that NSGP could be severely and permanently jeopardized.

To obtain FY 2025 NSGP Grant Guidance and government affairs and public policy updates, go to: https://spherestate.com/insights/tag/paid/.

Best,

Rob Goldberg
Principal
Goldberg & Associates, LLC
In partnership with Sphere State