FEMA hazard mitigation grants for nonprofits: HMGP, FMA and BRIC

Three programs, one direct route

FEMA's Hazard Mitigation Assistance (HMA) programs fund projects that reduce future damage from natural hazards. The rules for all three are in the HMA Program and Policy Guide v2.1, which applies to HMGP for major disasters declared on or after January 20, 2025. Who may apply is the first decision.

For FMA and BRIC, the HMA Guide (Part 4, B.3) says private nonprofits "are not eligible subapplicants," but an eligible subapplicant may apply on their behalf. That makes the local government the decision-maker, and its interest in sponsoring a nonprofit's building is the real gate.

HMGP: the program a nonprofit can use

HMGP funding "is available when authorized through a major disaster declaration" (HMA Guide v2.1, Part 2). An emergency declaration doesn't start it. Under 44 CFR 206.434(a), subapplicants include private nonprofits that own or operate a private nonprofit facility as defined in 44 CFR 206.221(e). The organization needs an IRS 501(c) ruling letter in effect on the declaration date, or state documentation of its nonprofit status. FEMA also checks that the facility provides a critical service, such as education or medical care, or an essential social service open to the general public. A private nonprofit school fits the educational category.

The organization doesn't need its own hazard mitigation plan. The jurisdiction where the project sits must have a current FEMA-approved local plan.

Florida's county gate

Florida adds a step that decides most outcomes. FDEM delegates project selection to each county's Local Mitigation Strategy working group (LMSWG), which, in FDEM's words, will "alone determine which eligible mitigation projects will be placed on their project priority list." Under Florida rule 27P-22.007, each application needs an endorsement letter from the working group's Chair or Vice-Chair. The letter must verify that the project appears in the current LMS and state its priority among the county's projects. FDEM's notices say an application without it will be denied, and a separate letter is required for each declaration.

FDEM announces each HMGP cycle with a Notice of Funding Availability in the Florida Administrative Register. The rule gives applicants at least 90 days from the notice, and FDEM sets the exact dates for each disaster. Applications go through FDEM's online portal, and FDEM's notices require the portal access request by 5:00 p.m. on the deadline day.

Houses of worship: an unresolved conflict

Two FEMA documents point in different directions, and a congregation should know both before it spends money on a mitigation application.

• FEMA's May 3, 2018 policy clarification, issued after the Bipartisan Budget Act of 2018, says a house of worship may be an HMGP subapplicant and that HMA will fund eligible activities for it "including retrofitting and elevation which primarily benefit the house of worship." It applies to major disasters declared on or after August 23, 2017.
• The current HMA Guide v2.1 lists as ineligible (Part 4, page 49): "Retrofitting facilities primarily used for religious purposes, such as places of worship (or other projects that solely benefit religious organizations)." It allows a place of worship only within an acquisition and demolition or relocation project that benefits the entire community.

The documents do not reconcile this conflict. Read plainly, the current Guide bars a wind or flood retrofit of a sanctuary, while the 2018 memo allows it. Before a house of worship asks its county working group to rank a retrofit, it should ask FDEM's mitigation program staff, in writing, which rule FDEM and FEMA will apply to that building, and keep the answer. A day school or community building on the same campus, used primarily for nonreligious services, may raise a different question; describe the building's actual use when you ask.

Houses of worship are eligible for Public Assistance after a major disaster, under separate rules. See FEMA Public Assistance for private nonprofits.

What HMGP can fund

FDEM's most recent notices (Joint NOFA, DR-4828 and DR-4834) list the eligible and ineligible activities. The ones most relevant to a nonprofit building:

Cost share. FEMA contributes up to 75 percent of the approved project cost, and the subrecipient provides the other 25 percent in cash or eligible in-kind contributions. Budget the 25 percent before you apply. FDEM's notices also describe a Global Match option, which gives credit for state or local government funds committed to similar projects.

Cost-effectiveness. A project must show a benefit-cost ratio of 1.0 or greater using FEMA's benefit-cost analysis, unless it qualifies for FEMA's pre-calculated benefits (HMA Guide v2.1, Part 5). Pre-calculated benefits exist for a short list of project types, including non-residential hurricane wind retrofits and generators for hospitals. Other projects need a full analysis, which takes engineering estimates and loss history, so start collecting damage records and repair invoices from past storms now.

Application and management costs

Pre-award costs

The HMA Guide (Part 3, D.4) allows pre-award costs directly related to developing a subapplication, such as gathering environmental data, preparing the benefit-cost analysis or preparing design specifications, subject to FEMA approval at award. The conditions are strict:

• For HMGP, only costs incurred after the date HMGP is authorized, generally the declaration date, qualify.
• Each cost must be a separate line item in the subapplication budget and can't be funded by another award.
• Applicants that are not selected receive no reimbursement for pre-award costs.
• In Florida, pre-award costs must be requested in writing with FDEM's signed pre-award request form at submission (FDEM Joint NOFA).

Pre-award costs are incurred at the organization's risk. They are reimbursable only if FEMA awards the project and authorizes the cost.

Subrecipient management costs

HMGP pays subrecipient management costs (SRMC) up to a hard cap of 5 percent of eligible and actual project costs, at 100 percent federal share, as a separate pool outside the benefit-cost analysis (FDEM Joint NOFA). FDEM requires a separate SRMC request form with the application. Under the HMA Guide, pre-award costs designated as management costs, such as developing the application and preparing the benefit-cost analysis, count toward the same 5 percent.

FDEM's SRMC guide lists eligible activities such as progress and financial reports, procurement compliance, reimbursement requests, closeout and record retention. Architecture, engineering, design and construction management are project costs, not management costs.

Procurement rules for consultants

A nonprofit subrecipient must follow 2 CFR 200.318 through 200.327 for every contract charged to HMGP, including applicable pre-award work under FDEM's notices. Competition must be full and open under 2 CFR 200.319. A contractor that drafts specifications or a statement of work for a procurement can't compete for that procurement. Professional fees may not be contingent on recovering federal money under 2 CFR 200.459, and 2 CFR 200.324 bars cost-plus-percentage-of-cost contracts.

The FY2026 FMA Swift Current notice applies the 2 CFR 200.319(b) restriction to contractors that help develop an application, project plan or budget. Federal funds can't pay that contractor for later work unless a compliant competition produced a contract that explicitly covers both development and execution. This condition governs FMA Swift Current. The HMA Guide v2.1 does not state the same extension for HMGP, so an HMGP applicant planning one firm for both stages should get FDEM's written direction before procurement.

FMA and BRIC through a local government

The FY2026 FMA Swift Current notice makes $600,000,000 available through activations tied to flood-related disaster or emergency declarations made between June 1, 2025 and May 31, 2027, including hurricanes. A state qualifies through its National Flood Insurance Program (NFIP) claims history. The notice says FEMA usually confirms eligibility within about 60 days of a declaration, and that each activation's application period has its own deadline. Eligible subapplicants are cities, counties, other local governments, special districts and tribes. The property must carry an NFIP policy and be a repetitive-loss or severe repetitive-loss property, or be NFIP-insured and substantially damaged; eligible work is acquisition, elevation and nonresidential floodproofing.

FDEM's FMA page ran a notice-of-interest period from July 13 to August 14, 2026 and says the application period is not open. BRIC's FY2024–25 round closed July 23, 2026, and the FEMA BRIC page lists only governments and tribes as applicants. For either program, a nonprofit's path is to ask its city or county to sponsor the project.

What to do now

The application periods identified in the status box are closed, and those sources give no date for another Florida window. An organization can prepare without assuming when another notice will appear:

• Find your county's LMS working group, learn when it meets and how it adds projects to its priority list, and ask how a private nonprofit submits one.
• Define the project: the building, the hazard, the measure and a written cost estimate. Collect records of past storm damage and repairs for the benefit-cost analysis.
• Confirm your IRS ruling letter, the facility's use, and the source of your 25 percent share.
• If you are a house of worship, get FDEM's written answer on the retrofit question before you invest in design.
• Adopt a written procurement policy and conflict-of-interest standards before you hire anyone whose costs you plan to claim.

For a future HMGP cycle, use FDEM's notice for that declaration to confirm the application period and submission rules.