Dear Nonprofit Security Friends:

Consistent with prior year’s appropriations. Congress included in the FY 2024 Homeland Security spending bill a timeframe by which FEMA was to promulgate key aspects of the NSGP application process. These requirements continued in FY 2025 as part of the year-long Continuing Resolution.

The requirements are (as taken from the FY 2024 spending bill, Page 536, Sec. 303, Committee Print H.R. 2882/Public Law 118–47):

• FEMA to release the Notice of Funding Opportunity to the State Administrative Agencies (SAAs) within 60 days from Congress’s enactment of the fiscal year’s Appropriations bill.
• The SAAs will have between 30 and 80 days to administer the applications to interested 501c3 organizations and submit eligible applications to FEMA for further review.
• Within this period, the SAAs will establish the period within which the 501c3s are to complete the IJ (deadlines may differ between SAAs).
• FEMA will have up to 65 days to make award recommendations to the Secretary of Homeland Security, who will make final award decisions.

Typically, FEMA announces final award decisions before September 1st.

For FY 2025, the “Full-Year Continuing Appropriations and Extensions Act” (P.L. 119-4) became law on March 15, 2025. Accordingly, the NSGP Notice of Funding Opportunity should have been released no later than May 15. The SAAs (and the nonprofit subrecipients) should have submitted their application to FEMA sometime between June 14 and August 3. FEMA should have made award recommendations to the Secretary of Homeland Security sometime between August 18 and October 7.

Discretionary annual appropriations technically have a 12-month authorization period (comprising the fiscal year commencing October 1 and ending September 30) within which period the administering department or agency is to commit the appropriated funds. If funds are uncommitted by the end of the fiscal year, they are to be returned to the Treasury.

With 48 hours before the deadline for FY 2025 tolled, the administration announced that it had committed the counterterrorism grants. This was more a gimmick than actual progress, as most grant award details were not published and key details and processes remain clouded under a veil of murkiness and uncertainty.

Moreover, the announcement, as it pertains to NSGP, did not follow precedent nor complied with the legislative requirements. The NOFO is incomplete. The SAAs and nonprofit subrecipients have not begun, completed, or submitted applications to FEMA for review. FEMA has not made subrecipient recommendations to the Secretary of Homeland Security and final decisions have not been made on subrecipient awards.

At this juncture, we can presume, but not verify, that the SAAs have received their target allocations for NSGP-Urban Area and NSGP-State funding streams, but that is as far as the FY 2025 program has advanced two months into the new fiscal year (FY 2026), and almost a month after the furthest deadline Congress legislated to complete the application and award processes.

What is the impact of these delays? Let’s review a case in point: Elevated threats in Alabama.

Under the FY 2025 NSGP NOFO, Alabama received a target allocation of $3 million, which remains in limbo. Based on recent threats in the State, this funding would otherwise have meaningful utility.

It has been reported that in 2023, at least five Jewish congregations in Alabama received emailed bomb threats and that in 2024, the ADL identified at least 67 antisemitic incidents in the State, including four incidents where Jewish institutions were targeted.

As many of you may have read, threats to Alabama’s Jewish institutions took a disturbing turn this week. According to multiple sources, Jeremy Wayne Shoemaker, 33, of Needham, Alabama, was arrested on Monday after the FBI and local law enforcement were alerted of “credible threats of violence” he made to local synagogues (in Alabama and neighboring states).

It was further reported that upon Shoemaker’s arrest, he possessed “weapons, more than a suitcase full of ammo, body armor and other items related to the plans of violence.” It was reported he resisted arrest and appeared he did not intend to be taken alive.

This remains an unfolding story and details about Shoemaker’s motivation and the threat events that led to his arrest have not yet fully come to light.

Alabama is considered a Republican stronghold at both the federal and state level. The Jewish population of Alabama is miniscule at about 18,000 (0.35%) of the State’s population of 5.2 million.

I share this data to underscore that the threats to the Jewish community can come from anywhere, in any geographic area in the country, no matter how small the community. This is why we worked so hard to establish the NSGP-State program in 2018 and ensured program resources would be evenly distributed between the NSGP-UA and NSGP-S programs, to ensure all communities — urban, suburban, and rural – would participate according to competitive (nonpartisan) and risk-based criteria.

Today, every community is hurt by the dysfunction with the state and local counterterrorism/preparedness grant programs. Whether New York or Alabama.

As I reported previously, in June 2025, the National Association of Counties (NACo) and the National Conference of State Legislatures (NCSL), which represent state and local elected officials, first responders, and those directly responsible for homeland security and emergency management in communities nationwide, sent a letter to the Department of Homeland Security and the Federal Emergency Management Agency to urge the executive branch to restart the preparedness grants.

They wrote that the delay has created “an inability to enhance response and recovery capabilities across the country and puts critical infrastructure at risk,” and “comes during a time when nation-state actors, domestic and international extremists, and the hazards of our natural environment pose a tremendous and increasing threat.” They added it was a matter of trust established over decades of work between federal, state, and local stakeholders.

In this void, there is an effort among congressional homeland security committee supporters of NSGP and the greater preparedness grant programs to address the serious problems of executive branch intransigence.

I have contributed my critique, comments, and recommendations to a number of the fixes that are in development, and I hope to be able to share details with you soon.

Best,

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