FEMA Public Assistance for private nonprofits and houses of worship

Which private nonprofits qualify

Public Assistance (PA) is FEMA's disaster grant for public infrastructure and for certain private nonprofit (PNP) facilities. Under the PAPPG v5.0, Chapter 3, which applies to incidents declared on or after January 6, 2025, a PNP must pass three tests. It must be an established private nonprofit, shown by an IRS 501(c) ruling letter in effect on the declaration date or by state documentation of nonprofit status. It must have owned or operated the facility when the incident happened. And the facility must provide an eligible service.

FEMA sorts eligible services into two groups, and the group decides how the organization applies.

• Critical services: education, utility, emergency and medical. A private K-12 school counts "as determined under state law," and the PAPPG says education facilities qualify "without regard to religious character or use for religious instruction."
• Noncritical, essential social services open to the general public: community centers, homeless shelters, libraries, museums, senior centers, and "houses of worship and faith-based organizations (e.g., churches, synagogues, mosques, and temples)."

FEMA announced on January 2, 2018 that houses of worship are eligible, and the Bipartisan Budget Act of 2018 added them to the Stafford Act's list of eligible facilities (FEMA PNP fact sheet). FEMA treats a house of worship like any other noncritical PNP. It can't be ruled ineligible because membership or leadership is limited to people who share a faith. Facilities used primarily for political, athletic, recreational, vocational, conference or retreat activity are not eligible.

The SBA-first rule for noncritical facilities

A PNP whose facility provides only noncritical services must apply for a U.S. Small Business Administration (SBA) disaster loan before FEMA funds its permanent work. FEMA then pays only for permanent work the SBA loan won't cover (PAPPG v5.0, Chapter 3, Table 2). If the organization misses the SBA deadline, the permanent work is ineligible for PA. If it declines an approved loan, PA covers only what the loan would not have covered.

The SBA step doesn't apply to emergency work (debris removal and emergency protective measures), and it doesn't apply to a facility that provides a critical service, such as a private school, even if the facility also provides noncritical services. In practice, a church, synagogue or mosque has to run two applications at once: the PA request to FEMA and the loan application to SBA.

Emergency declarations and major disaster declarations

The President's declaration sets what FEMA can pay for, area by area. The two kinds of declaration authorize very different things.

Direct federal assistance (DFA) is work performed by a federal agency under a mission assignment when state and local governments can't perform or contract eligible emergency work (PAPPG v5.0, Chapter 5, section XIV). EM-3655 authorizes Category B emergency protective measures limited to DFA. It does not authorize permanent repairs. Ask FDEM whether any assistance under that declaration applies to your facility before preparing an RPA or claim.

What FEMA can fund: Categories A through G

FEMA groups PA work into seven categories. Categories A and B are emergency work. Categories C through G are permanent work, which requires a major disaster declaration.

For a house of worship or school, most permanent work falls in Category E. Where a facility is used for both eligible and ineligible purposes, FEMA looks at the use of more than 50 percent of the space and can prorate funding by the eligible share (PAPPG v5.0, Chapter 3).

The Request for Public Assistance

The Request for Public Assistance (RPA) is the organization's notice to FEMA that it intends to apply. It isn't a competitive application, and it doesn't list costs yet. Under 44 CFR 206.202 and the PAPPG, an applicant must submit the RPA through FEMA's PA Grants Portal within 30 days after its area is designated. The clock runs from the county's designation, which can come later than the declaration itself if FEMA adds counties.

FEMA's Regional Administrator may extend the deadline on written justification of circumstances beyond the applicant's control. The PAPPG's examples include an applicant whose only work falls in categories added after the initial declaration. Don't count on an extension: ask for it in writing, before the deadline, through the state.

In Florida, FDEM is the recipient and runs the program. FDEM's Public Assistance page tells applicants to register in Grants Portal and submit the RPA there, and it also names the state's FloridaPA.org portal for submissions and extension requests. FDEM's page is not consistent on which system takes the RPA first, so confirm the route with FDEM when a declaration is made. The state must hold applicant briefings "as soon as possible" after a declaration (44 CFR 206.207); attend one if your county is designated.

1. Declaration and designation.The President declares, and FEMA designates counties for specific PA categories.
2. Applicant briefing.FDEM explains the process and deadlines to potential applicants.
3. RPA.The organization submits the request in Grants Portal within 30 days after its county is designated.
4. Eligibility and damage review.FEMA confirms the organization and facility are eligible and meets with the applicant. Under 44 CFR 206.202(d), the applicant has 60 days after that first substantive meeting to identify and report its damage.
5. Projects and obligation.FEMA writes projects, and the state pays the subrecipient as FEMA obligates funds.

Work deadlines run from the declaration date: 6 months for debris removal and emergency work and 18 months for permanent work, with extensions available from the state and then FEMA (44 CFR 206.204).

Documents to gather

FEMA's list for PNP applicants is in PAPPG v5.0, Table 6. Most of it exists before a storm, so you can assemble it now:

• Proof of nonprofit status: the IRS ruling letter, or state documentation, in effect on the declaration date.
• Proof of legal responsibility for the facility: a deed, tax bill, mortgage record or insurance policy, or the lease if you rent.
• A description of the services in the damaged facility, when they happen and who they serve.
• For a house of worship: who may join, any membership fees, and the fee-waiver policy.
• For a school: proof of state accreditation or recognition, compulsory-attendance compliance, the calendar, the budget, and enrollment and faculty counts. For child care, the state license.
• After the event: dated photos of damage and debris, a work log, invoices, contracts, the procurement file, and every insurance record.

Insurance and duplication of benefits

FEMA and SBA can't pay for a loss that insurance covers. Applicants must pursue the insurance claims they are entitled to, and FEMA reduces eligible costs by insurance proceeds (PAPPG v5.0, Chapter 3 and Chapter 5). For a well-insured building, the remaining claim may be the deductible and any uncovered items. File the insurance claim at once and keep the adjuster's report and the settlement letter; FEMA will ask for both.

The obligation also runs forward. An organization that receives PA funding for permanent work on an insurable facility must obtain and maintain insurance against the hazard that caused the damage, for the anticipated life of the repair or of the facility, whichever is shorter. It's a condition of the grant. If you can't carry that coverage, raise it with FDEM before you accept the funding.

Procurement and reimbursement

PA is a reimbursement program. The organization pays its contractors, documents the work, and receives funds as FEMA obligates projects and the state processes payments. Plan cash for that gap.

A private nonprofit subrecipient must follow the federal procurement standards in 2 CFR 200.318 through 200.327, including full and open competition under 200.319 and a written procurement policy. If a contract doesn't comply, FEMA can deny all costs under it or pay only the portion it finds reasonable (PAPPG v5.0, Chapter 5, section X). The same chapter limits time-and-materials contracts to cases with no suitable alternative, a ceiling price and close oversight, and it bars cost-plus-percentage-of-cost pricing. Noncompetitive contracts are possible only under the exceptions in 2 CFR 200.320(c), such as a genuine emergency, and only for as long as the emergency prevents competition.

The purchase methods and thresholds are the same federal rules that apply to security grants, described in our procurement guide. The claim records FEMA expects follow the same logic as the reimbursement guide: a paid invoice, proof of payment, and the procurement record behind every cost.

Management costs

FEMA pays a separate amount for the work of developing and managing PA projects. For a subrecipient, FEMA pays actual management costs up to 5 percent of the subrecipient's total award, at 100 percent federal share, through a Category Z project (PA Management Costs Interim Policy, FP 104-11-2; 44 CFR Part 207). The 5 percent is tied to obligated projects: once a subrecipient has project obligations, FEMA may obligate 5 percent of that total. With no obligated project, there is nothing to take a percentage of.

Eligible management activities include preparing projects, meetings, correspondence, site inspections, collecting documents and preparing reimbursement requests. The claim must show actual, reasonable costs, supported by procurement procedures, contracts and invoices.

Rules for consultant costs

• Under 2 CFR 200.459, professional service fees must be reasonable and may not be contingent on recovering costs from the federal government. 2 CFR 200.324 also bars cost-plus-percentage-of-cost contracts.
• A consultant whose cost will be charged to PA must be selected under 2 CFR 200.317 through 200.327. Competition must be full and open. A noncompetitive contract with a consultant on retainer is a restrictive practice under 2 CFR 200.319(c), and a contractor that drafts specifications or a statement of work can't compete for that procurement under 2 CFR 200.319(b).
• Eligible grant-management work is limited to actual, reasonable costs within the 5 percent subrecipient management-cost cap. Engineering or design directly attributable to a repair belongs to that project, not Category Z.
• A cost incurred before an award or obligation is reimbursable only if FEMA and FDEM authorize it under the award and find it allowable. An organization that incurs the cost earlier bears the risk that it will not be reimbursed.

Complete the required procurement before the consultant starts work that the organization intends to charge to PA, and retain the solicitation, bids or proposals, evaluation, contract, invoices, and proof of payment.

What to do before a declaration

No RPA clock runs until a county is designated, but most of the work can start now. Assemble the Table 6 documents, photograph the facility and its contents, keep a dated log of storm work and costs, and open the insurance claim. Adopt a written procurement policy if you don't have one. If your organization is a house of worship, find the SBA disaster loan process in advance so the loan application doesn't slow the FEMA request.

Repairs also create a chance to reduce future damage. For hazard mitigation after a major disaster, including the Hazard Mitigation Grant Program, see our guide to FEMA mitigation grants for nonprofits.