Church eligibility and scoring under NSGP
A church submits to its State Administrative Agency (SAA), not directly to FEMA. The FY2026 notice of funding opportunity (NOFO) says a church that meets the section 501(c)(3) requirements doesn't need an IRS recognition letter. The SAA scores the Investment Justification (IJ) on the 40-point matrix in Appendix D and validates the organization type against its mission statement. During federal review, FEMA applies the ×3 multiplier for a house of worship and adds 15 points if the applicant has never received a federal NSGP award. Religious affiliation itself gets no preference. See the NSGP program hub for other eligibility rules and the application guide for the state submission sequence.
Which entity applies: congregation, parish, or diocese
The worshipping congregation isn't always the entity that holds the exemption, bank account, or deed. Confirm the applicant's legal name, Unique Entity ID (UEI), SAM.gov registration, signing officers, and property interest before drafting.
Structures differ even within one tradition. The Archdiocese of Omaha's parish handbook says each parish "is a separate civil corporation." The Archdiocese of Los Angeles administrative handbook says its parishes aren't separate civil-law entities and that a corporation sole generally holds title. In the United Methodist Church, ¶2501 of the Book of Discipline places local church property "in trust" for the denomination.
The Authorized Organization Representative (AOR) must be the applicant nonprofit's own officer or employee; a consultant can't serve as AOR. The limits of three sites per funding stream and $600,000 per organization per state also attach to the legal entity. If several parishes share one entity and UEI, get the SAA's written direction before they submit separate site applications.
A denominational group exemption can supply proof if the state requests it. Catholic organizations listed in the Official Catholic Directory, for example, fall under the group ruling held by the U.S. Conference of Catholic Bishops. A denomination may also require internal approval. Under canon 1281, the statutes or diocesan bishop define which acts exceed ordinary administration and require written authority. Ask the diocese, conference, presbytery, or synod what must be approved before signing a security contract or changing the building.
Who owns the building, and who else uses it
Allowable security equipment must be installed on real property "owned or leased by the nonprofit organization" (FY2026 NOFO, Appendix A). The IJ asks a tenant whether the owner approved the proposed work. When a diocese, conference, or trust holds title, get its written approval before submitting. Florida also requires a notarized property-interest document before hardening work starts (see Florida security grants).
The FY2026 IJ form posted on Grants.gov and New York's FY2026 FAQ state the shared-building rule plainly:
"Only one nonprofit can apply per building/facility/physical structure/address. However, the request and subsequent security enhancements may benefit nonprofits who cohabitate/operate in/from the same location. Multiple requests for federal assistance from the same physical address/building/facility/structure will all be deemed ineligible."
If the building hosts a school, preschool, food pantry, recovery group, or another congregation, settle who applies before the window opens.
| Situation | Who can apply for that building | What to confirm first |
|---|---|---|
| The school, preschool, or pantry is a ministry of the church, with no separate legal entity | The church, as one applicant for the site | The vulnerability assessment and IJ cover the building's users |
| A school or daycare in the building is its own nonprofit | One of the two, not both | Agree in writing which one will run the award, procurement, and reimbursement. See private school security grants. |
| Another congregation rents the sanctuary | One applicant for the building | The IJ explains how the work protects both congregations |
| A for-profit business or public agency also uses the space | The church, if it otherwise qualifies | The NOFO bars the direct or indirect pass-through of benefits to ineligible entities. Ask the SAA how that rule applies to the shared use. |
| The church rents space, such as a school auditorium on Sundays | Ask the SAA before applying | The applicant must be "actively occupying and functioning out of" the site. Confirm that part-time use qualifies and get the owner's written approval. |
For campuses with several buildings, FEMA's FY2025 FAQ defines a site as "a singular address or physical building," while New York's FY2026 FAQ requires each site to have "a separate and distinct street address." Ask the SAA how it counts a sanctuary, parish hall, and school on one lot before dividing the campus into applications.
Older sanctuaries and environmental review
Federal law requires environmental and historic preservation (EHP) review before FEMA releases funds for covered work. FEMA's EHP screening form asks the building's age, later modifications, and whether structures at least 50 years old stand in or next to the project area. A building more than 45 years old also needs exterior photos. Work on a property in a historic district or listed on the National Register may require consultation with the State Historic Preservation Office.
For a church, review may reach cameras and lights anchored to masonry, replacement doors, film on older windows, fencing, and bollards or light poles that require digging. Describe the full scope on the screening form and allow for review in the IJ milestones. Entry or vestibule remodeling may be construction or renovation, which requires FEMA's prior written approval under the NOFO. See the EHP review guide.
Safety teams and volunteer training
The FY2026 NOFO allows training for employed or volunteer security staff, train-the-trainer courses, and on-site training for employees and congregants. Allowable subjects include active-shooter response, emergency first aid, Stop the Bleed, Community Emergency Response Team (CERT), and defibrillator (AED) training. Attendance fees, materials, and supplies are allowable; overtime, backfill, and travel aren't.
Identify each course, its audience, and the weakness from the vulnerability assessment that it addresses. Volunteer-team equipment also needs that link. For example, the FY2026 Authorized Equipment List includes portable radios for notifications and alerts (AEL 06CP-01-PORT), but federal funds can't buy radios for a contracted guard company. The Cybersecurity and Infrastructure Security Agency's performance goals for faith-based communities recommend a named security lead, screening for volunteers, and a waiting period before they take key roles. FEMA's planning guide for houses of worship provides a model for the emergency plan.
Paid security: off-duty officers and guard companies
The FY2026 NOFO allows a subrecipient to use up to 100% of its award for contracted security personnel, who must comply with Information Bulletin 441. It bars hiring public safety personnel but permits off-duty law enforcement working as contract security. An existing Sunday detail is still a contract subject to federal procurement rules. The security guard guide covers the IJ detail, licensing, records, and reimbursement.
A church may also ask its police department about patrols. The FY2026 Byrne Justice Assistance Grant (JAG) solicitation lets local agencies use funds "to respond to and deter threats to houses of worship" (Justice Department, FY2026). The city or county, not the church, applies for JAG; FY2026 local applications are due October 16, 2026.
Board oversight and award records
A church that buys informally should have its vestry, session, council, or board adopt written procurement and conflict-of-interest standards before the first grant purchase. If a member's firm bids, anyone with a financial interest must stay out of the selection, and no one involved may accept a vendor gift or favor. The procurement guide covers the federal rules.
Volunteer roles rotate, so at least two people should understand the award file. If the AOR leaves, appoint a new authorized representative through the state. See reimbursement requests for the claim process.
Other federal and state money for churches
The Department of Justice ran a separate 2026 program, Enhancing Security Measures for Houses of Worship. Category 1 let faith-based organizations apply directly for camera systems of up to $200,000; the $4 million competition anticipated about 20 awards. It closed September 9, 2026, and no FY2027 notice had appeared by October 14. The program required partner agreements, an assessment conducted with local police, and an agreement governing police access to video. It also allowed facial-recognition capability. Only governments could apply under Category 2, which paid police overtime at houses of worship.
States also fund houses of worship directly. The table highlights programs that change a church's options; security grants by state lists every state.
| State | Program | What matters for a church | Status |
|---|---|---|---|
| Georgia | Funds for Protection of Communities | Georgia nonprofits exempt under section 501(c). No match. Work must fit October 1, 2026 to June 1, 2027. | FY2027 round open: $5 million, due October 30, 2026, at 11:59 p.m. The earlier 2026 round, with awards from $25,000 to $150,000, closed May 22, 2026. |
| Tennessee | Houses of Worship Security Grant | Pays for contracted security personnel only, by reimbursement, over 12 months. Groups with federal NSGP guard funds are not eligible. | 2026–27 round closed August 3, 2026 |
| Washington | Religious and Nonprofit Security Grant | Run by the Department of Commerce, not the NSGP agency | Current round awarded through June 2027. Next round not announced. |
| Maine | Maine Nonprofit Security Grant | Lists religious institutions as eligible. $25,000 per site, up to three sites, no cost share. | Closed August 23, 2026 |
| Connecticut | Connecticut Nonprofit Security Grant | The applicant must own the building, so check title first if you rent or use diocesan property. $50,000 per site. | Closed September 14, 2026. Next round depends on bond funding. |
| Virginia | Combating Hate Crimes Grant | Pays for target hardening, security equipment and guard services. About $1,000,000 statewide. | Round 2 closed August 18, 2026 |
CISA's December 2023 performance goals for faith-based communities say its Protective Security Advisors support faith-based communities "with vulnerability assessments, site visits, and training at no cost," and its houses of worship page offers a self-assessment. A diocesan, conference, or synod facilities office may also hold the deed or control building approvals, so contact it early.
Frequently asked questions
If another parish in our diocese won NSGP before, do we lose the first-time bonus?
Not necessarily. FEMA adds 15 points for a subapplicant that has never received a federal NSGP award, and the IJ asks for the applicant's own history (FY2026 NOFO). If the parishes are separate legal entities, one parish's award is not the other's. If they share one legal entity, ask the SAA how to report that history.
Sources
- FEMA, FY2026 Nonprofit Security Grant Program NOFO
- FEMA Information Bulletin 441, contracted security personnel (June 6, 2019)
- Grants.gov, FY2026 NSGP posting and Investment Justification form FF-207-FY-21-115
- New York DHSES, FY2026 NSGP Frequently Asked Questions
- FEMA, FY2025 NSGP Frequently Asked Questions
- FEMA, Environmental and Historic Preservation Screening Form FF-207-FY-21-100
- DOJ BJA, FY2026 Enhancing Security Measures for Houses of Worship NOFO
- DOJ BJA, FY2026 Byrne JAG Local Formula solicitation
- CISA, Physical Security Performance Goals for Faith-Based Communities (December 2023)
- CISA, Protecting Houses of Worship
- FEMA, Guide for Developing High-Quality Emergency Operations Plans for Houses of Worship
- USCCB, Group Ruling FAQ
- Code of Canon Law, canons 1254–1310 (canon 1281)
- Archdiocese of Omaha, Parish Business Administration Handbook (2021)
- Archdiocese of Los Angeles Administrative Handbook, 2.2.2 Civil Law Structure
- United Methodist Church, Book of Discipline ¶2501
- Tennessee Department of Safety and Homeland Security, grant programs
- GEMA/HS, Georgia Funds for Protection of Communities
- Washington Department of Commerce, Religious and Nonprofit Security Grant
- Maine Emergency Management Agency, Maine Nonprofit Security Grant Program
- Connecticut DEMHS, Connecticut Nonprofit Security Grant Program
- Virginia DCJS, FY2027 Combating Hate Crimes Grant Program, Round 2