What NSGP pays for: allowable costs and AEL codes

What NSGP funds can pay for

FEMA's FY2026 notice of funding opportunity (NOFO) allows planning, equipment, training, and exercises, contracted security, maintenance, certain construction, and the cost of managing the award. Appendix A (pp. 58–67) controls each category. Organization costs are not allowed.

Each project must "[a]ddress an identified risk, including threat and vulnerability" (p. 27). The State Administrative Agency (SAA) scores whether an item is "tied to a vulnerability that it could reasonably address/mitigate" (Appendix D, p. 75). An item on the equipment list still needs a matching finding in the site's vulnerability assessment.

How the equipment list works

The Authorized Equipment List (AEL) is FEMA's catalog for preparedness grants. NSGP uses the 36 codes printed in Appendix A of the FY2026 NOFO. FEMA limits the list to facility hardening and physical security enhancements; equipment outside it requires FEMA's prior approval (pp. 58–64). FEMA's online AEL pages sometimes word an item differently: the 14SW-01-SIDV page is titled "Systems, Vehicle Identification and Tracking," while the NOFO title is "Systems, Vehicle Identification." The 14SW-01-LITE page describes "building perimeters and surveillance zones," while the NOFO says "building perimeters, parking lots, and other critical zones." For NSGP, the NOFO's text controls.

A code establishes the equipment category, not approval of the project or purchase. These conditions still apply:

• The project must appear in the approved award and address the vulnerability identified for that site.
• Installation may require environmental and historic preservation (EHP) clearance before work starts. Some installations count as construction or renovation. See the EHP review requirements.
• The nonprofit must follow the applicable rules for competition, specifications and conflicts of interest. See NSGP procurement requirements.
• The equipment must go on property the nonprofit owns or leases and meet applicable standards, including the Americans with Disabilities Act (pp. 58, 64). FEMA's FY2024 NSGP FAQ adds that work must be permissible by the property owner.

The post-award guide covers the sequence from the subaward agreement through closeout.

NSGP AEL codes: the full FY2026 list

Appendix A of the FY2026 NOFO (pp. 59–63) contains 36 codes. Section IV-B of the Investment Justification (IJ) uses them as budget choices, along with non-AEL lines for guards, planning, exercises, and M&A. One project may use several codes. A camera project, for example, may use 14SW-01-VIDA for cameras, 04AP-06-VIDA for analytics, and 21GN-00-INST for installation.

Cameras, video, alarms, and detection

Access control, ID, and screening

Doors, barriers, glass, lighting, and signs

Alerts, public address, intercoms, and radios

Backup power

Cybersecurity and IT

Installation, training, and other budget lines

Installation and training have AEL codes. Planning, exercises, guards, and M&A appear in the IJ but are not part of the AEL.

Restrictions on cameras, analytics, and network gear

The FY2026 NOFO bars license plate reader and facial recognition software, while expressly allowing software that detects weapons through video analysis (pp. 59, 62–63). FEMA's AEL entry for 14SW-01-VIDA carries the same NSGP restriction.

Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 also restricts covered telecommunications and video-surveillance equipment and services. The rule at 2 CFR 200.216 reaches covered manufacturers, subsidiaries, affiliates, and certain systems that use covered equipment as a substantial or essential component or as critical technology. For Hytera, Hikvision, and Dahua equipment, the regulation adds a purpose phrase: "public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes." The rule applies to subrecipients, contractors, and subcontractors, and FEMA-funded contracts must carry the required provision (FY2026 NOFO, pp. 17–18). Under 200.216(e), a subrecipient certifies compliance when it accepts the award, and the rule says no further certification is required beyond that one and those provided with payment requests and financial reports.

Before buying cameras, recorders, radios, or network gear, get the manufacturer and model number of each quoted component and put the Section 889 provision in the contract or purchase order. The security camera guide explains the component check. Subscriptions, licenses and warranties also have a timing limit under the FY2026 Preparedness Grants Manual (section 3.3): coverage bought with the original equipment may extend beyond the performance period when that term is normal, but a later stand-alone purchase or renewal may not.

What does NSGP not pay for?

The FY2026 NOFO lists these projects and costs as ineligible for award consideration (p. 17):

• Organization costs, operational overtime, overtime and backfill.
• Hiring public safety personnel, except off-duty law enforcement working as contract security.
• General-use expenditures.
• Initiatives that do not build prevention or protection capabilities at identified facilities or surrounding communities.
• Developing risk or vulnerability assessment models, funding risk or vulnerability security assessments, or developing the Investment Justification.
• Work that benefits federal agencies or improves federal property.
• Technology studies and proof-of-concept initiatives.
• Direct or indirect pass-through of benefits to ineligible entities.

FEMA also bars using its award as match for another federal grant, for lobbying or to pursue a claim against a government (p. 17). Because the NOFO does not define "general use expenditures," tie any item with everyday uses to protection against the terrorist or extremist risk in the site's assessment. Subrecipients cannot claim pre-award costs (p. 19).

Training, planning, and exercises

NSGP may pay for security training attended in the United States by employed or volunteer security staff, staff who will train others, and employees or members trained on site. Allowable costs include attendance fees, materials, supplies and equipment. Overtime, backfill and travel are not allowable (FY2026 NOFO, p. 65).

Allowable topics include physical and cybersecurity, facility hardening, extremist-threat awareness, Community Emergency Response Team training, active-shooter response and emergency first aid. The NOFO also names Stop the Bleed, novice first aid, automatic external defibrillator and basic life support training and kits (pp. 65–66). The training must address a threat or vulnerability in the IJ.

Planning may cover security plans and protocols, emergency contingency plans, evacuation or shelter-in-place plans and coordination with fusion centers (p. 58). The NOFO lists "Development or further strengthening of security assessments" here but separately bars initiatives that fund risk or vulnerability security assessments. Ask the SAA how it applies that distinction before budgeting assessment work.

Allowable exercise costs include planning, meeting space, facilitation, materials and documentation (p. 66). FEMA directs exercise programs to the Homeland Security Exercise and Evaluation Program and calls for identified gaps to be tracked in an improvement plan.

Guards, maintenance, construction, and administration

Contracted security personnel are allowed. The FY2026 NOFO permits a subrecipient to use up to 100% of its award for contracted security, requires compliance with Information Bulletin 441 and bars buying equipment for contracted security (p. 67). Off-duty law enforcement may work as contract security. The security guard grants guide covers procurement and service records.

Maintenance and sustainment may include maintenance contracts, warranties, repairs or replacement, upgrades and user fees (p. 66); the Preparedness Grants Manual (section 3.3) adds licenses. Under the manual, the cost must directly support an existing capability and otherwise comply with NSGP rules. It may support equipment bought with other funds. The manual's time limit on stand-alone warranties and extended maintenance contracts "extends to licenses and user fees, as well." Neither the NOFO nor the manual addresses central-station alarm monitoring or live video monitoring, so ask the SAA in writing before budgeting a monitoring fee.

Construction and renovation require FEMA's prior written approval; equipment installation may qualify as either (pp. 66–67). Approved work requires SF-424C and SF-424D. The NOFO states that its total cost may not exceed "the greater amount of $1 million or 15% of the NSGP award." Ask the SAA before budgeting structural work.

A nonprofit may use up to 5% of each subaward for management and administration (p. 19). Examples include required reports, equipment inventory, expenditure records and responses to oversight requests. An organization with several subawards must account for each subaward's M&A separately.