Changing an NSGP project: budget moves, scope changes and more time

Budget change or scope change

The type of change determines who must approve it. A scope change alters what the project is or does, such as a different security measure, a new site, or a new objective. Federal rules require prior written approval for any "Change in the scope or the objective of the project or program," even when no budget revision is involved (2 CFR 200.308(f)(1)). For NSGP, FEMA makes that decision (Preparedness Grants Manual, section 9.2). The post-award roadmap shows where change approval fits with EHP review, procurement, and reimbursement.

A budget change moves money between approved lines without changing the work, for example when one approved item comes in under its estimate and another comes in over. FEMA's Preparedness Grants Manual, section 9.2, says a subrecipient "simply making changes to its own budget without impacting the scope or objective of the subaward" needs no prior approval from the SAA or FEMA, as long as no other prior-approval rule applies. It must report the change to the SAA.

The subaward can add prior approvals: 2 CFR 200.332(b) lets the SAA include additional requirements. Published SAA guidance requires a written request or approval before at least some budget moves. Missouri's FY2024 workshop, for example, treats a new line item, quantity change, or specification change as a scope-of-work change (Missouri DPS, FY2024 NSGP Compliance Workshop). Follow the signed subaward and the SAA's written direction.

Do not rely on a 10 percent cushion. 2 CFR 200.308(i) lets FEMA restrict transfers when the federal share exceeds the simplified acquisition threshold and cumulative transfers exceed 10 percent of the budget. The simplified acquisition threshold has been $350,000 since October 1, 2025 (FY2026 NOFO). The sources reviewed do not say how FEMA measures that test for an NSGP subaward. Use the subaward rule and ask the SAA before moving funds.

How a scope change request moves

A nonprofit can't send a change request to FEMA itself. FEMA's manual sets this sequence for an NSGP scope or objective change (Preparedness Grants Manual, section 9.2):

1. The subrecipient writes to the SAA.The request, on the organization's letterhead, lists the approved projects and their funds, the proposed changes and any reallocation, why the change is necessary, and whether it affects completion within the period of performance.
2. The SAA validates it.The SAA confirms that any deviation from the approved Investment Justification (IJ) is addressed in the vulnerability assessment the subrecipient submitted with its application.
3. The SAA submits it.The request goes to FEMA through FEMA GO as a "Scope Change Amendment."
4. FEMA decides.FEMA considers requests "on a case-by-case basis, provided the change does not negatively impact the competitive process," and "may reject requests to significantly change the physical security enhancements" it funded.
5. The SAA modifies the subaward.The subrecipient may not start the changed work until the SAA receives FEMA's written approval and makes any required subaward modification.

When the subaward requires a budget-only request, use the SAA's form and process. Florida's FY2023–2024 onboarding guide asks for a written request with "a revised Program budget and the Budget Detail Worksheet (BDW)" to reallocate funds between approved projects (FDEM, NSGP Onboarding Process). California's FY2024 supplement routes budget and scope changes through a workbook signed by the organization's authorized agent, and allows the related expenses "only after receiving written final approval" (Cal OES, FY2024 NSGP California Supplement).

For a revision that the SAA reviews, 2 CFR 200.308(d) says it should notify the subrecipient within 30 days whether the revision is approved. If review takes longer, the SAA must give a written expected decision date. A scope change still waits on FEMA's decision.

When the subaward or another rule requires prior approval, spending first can lead to disallowance. For a budget-only change covered by section 9.2 of the Preparedness Grants Manual, report it in the form and timing the SAA directs.

Substituting equipment

A substitute has to pass the same tests as the original. It must fit an allowable category on FEMA's Authorized Equipment List (AEL), or FEMA must approve it in advance (NOFO, Appendix A, Equipment); the allowable costs guide covers the list. It must also answer the vulnerability the award was based on, because the SAA has to confirm that any deviation from the approved IJ is addressed in the site's assessment. Florida's FY2023–2024 onboarding guide says: "New projects being proposed must have been identified in the vulnerability assessment."

Before ordering a substitute, also check:

• Environmental review. A new item or a different installation may need its own environmental and historic preservation (EHP) clearance. Missouri's FY2024 workshop says that if the project scope changes, "another EHP form must be approved prior to work beginning." See NSGP EHP review.
• Cost and construction approvals. A new special-purpose equipment item costing $10,000 or more per unit needs prior written approval under 2 CFR 200.439(b)(2). An item already in the approved budget may already have that approval, so ask whether a substitute needs fresh approval. General-purpose equipment and an installation that materially increases a capital asset's value or useful life require prior approval under paragraphs (b)(1) and (b)(3). The FY2026 NOFO also requires FEMA's prior written approval for construction or renovation.
• Procurement. The purchase of the substitute must follow the applicable federal rules and the organization's written procedures. See NSGP procurement requirements.

When quotes come in over budget

Plan as if the approved amount is the ceiling. Federal rules require prior approval when "The need arises for additional Federal funds to complete the project" (2 CFR 200.308(f)(8)), but neither the FY2026 NOFO nor FEMA's Preparedness Grants Manual describes a way to increase an NSGP subaward after it is made (checked October 14, 2026). The practical options are:

• Reduce the scope, with approval. Fewer units or a smaller installation changes the approved project, and Missouri's FY2024 guidance treats a quantity change as a scope-of-work change. Ask the SAA before ordering.
• Move money from another approved line. That is a budget change, which your subaward may require the SAA to approve first.
• Pay the difference with the organization's own funds. Confirm with the SAA whether the approved budget or scope must change. Federal reimbursement remains limited to approved costs and amounts, and the purchase still follows the applicable procurement rules.

Savings and leftover funds

Neither the FY2026 NOFO nor FEMA's Preparedness Grants Manual addresses project savings directly. Published SAA guidance shows the practice: Missouri lists "Adding new line items to the approved budget" as a scope-of-work change, while Florida allows budget modifications that "reallocate funds between approved projects." Spending savings on an item that isn't in the approved budget, without written approval, puts that cost at risk of disallowance.

There is no later budget period to carry savings into: the FY2026 award has "only a single budget period with the same start and end dates as the period of performance" (NOFO, Budget Period). At closeout, the SAA deobligates unused balances. A subrecipient must promptly refund unobligated funds already paid to it and not authorized to be retained (2 CFR 200.344(e)–(f)). If you expect savings, ask the SAA early whether it will consider a reallocation or scope change. NSGP reporting and closeout explains the final reconciliation.

Changing the site or the building

Each NSGP Investment Justification is tied to one address. It must cover the physical address the nonprofit "occupies at the time of application," and each site needs its own vulnerability assessment (NOFO, Eligibility and IJ requirements). FEMA's Preparedness Grants Manual, section 9.2, says it "will generally not approve" a scope change from a subrecipient that renovates after applying where the renovation "would affect the vulnerability/risk assessment upon which the IJ is based."

Equipment already bought stays tied to its approved use. While it serves that purpose, the organization "must not dispose of or encumber its title or other interests without the approval" of FEMA or the SAA (2 CFR 200.313(a)(2) and (c)(1)). Before you move, remove or sell grant-funded equipment, or sign a lease or renovation contract that affects the site, ask the SAA in writing.

Asking for more time

First identify which date must move. FEMA's manual governs an extension of the federal award period of performance. The SAA submits a formal written request to FEMA, and the manual says it should arrive at least 120 days before the federal period ends. Extensions "are typically granted for no more than a six-month period" (Preparedness Grants Manual, section 6.3).

The sources reviewed do not say whether changing only the subaward end date, while staying inside FEMA's period, requires FEMA approval. Ask the SAA which date needs to move and follow the request deadline in the subaward. California's FY2024 supplement, for example, required a subrecipient's request at least 60 days before its own period ended (Cal OES, FY2024 supplement).

The request must give the reason for the delay, current status, proposed completion date, funds drawn and remaining, a budget for the balance, and a completion plan with milestones and a responsible person. FEMA's Preparedness Grants Manual, section 6.3, limits extensions to vendor contract commitments, a complex environmental review that can't finish in time, projects that are long-term by design, or other special or extenuating circumstances. The request must also certify that the work will be completed "without any modification to the original statement of work." A separate scope-change request is needed if the work will change.

Until FEMA approves the extension and the SAA makes any required subaward amendment, the existing end date remains in force.

Moving funds to contracted security

The FY2026 NOFO lets a subrecipient use up to 100% of its subaward for contracted security personnel, requires compliance with Information Bulletin 441, and bars using NSGP funds "to purchase equipment for contracted security" (NOFO, Appendix A, Contracted Security Personnel). If guards were not part of the approved project, ask the SAA how to submit the budget and scope change before obligating funds. The guard contract must follow the applicable procurement rules, including competition unless a permitted noncompetitive method applies; see security guard grants.

Personnel and contact changes

The FY2026 NOFO says that "Anytime there is a change in personnel" for a subrecipient, the person's information must be submitted for approval (NOFO, Additional Reporting Requirements). Separately, a change in key personnel named in the award needs prior written approval under 2 CFR 200.308(f)(2).

The NOFO doesn't say who approves the change or on what form. Missouri's FY2024 workshop lists changes in an authorized official, project director, or fiscal officer as program modifications the state must approve before funds are obligated or spent. Tell the SAA in writing when the authorized representative, signer, project lead, or finance contact changes, and ask which form it uses.