The U.S. Department of Homeland Security (DHS) released its initial guidance today. The New York Department of Homeland Security and Emergency Services (DHSES) hopes to have the necessary approvals and release their Request for Applications sometime next week. We’ve begun to update our webpage www.jcrcny.org/securitygrants with the 2014 material.

The application package for New York nonprofits will be due around the end of April, possibly as late as May 9th. DHS should announce the results at the end of July. The DHS materials are available here. Remember: The “applicants” referred to in the links on the DHS page are the state agencies. All organizations are bound by the requirements of and dates set by New York DHSES. The New York materials will be available at http://www.dhses.ny.gov/grants/nonprofit.cfm when they are approved.

The big change this year is that New York nonprofits must pre-qualify (see below), which may take several weeks (see below). While completing the pre-qualification process, organizations should assemble the materials for their Investification Justification (see here). Get started now!

New York’s new requirement: pre-qualification

Applications from New York nonprofit organizations that have not “pre-qualified” will not be considered, so we recommend that you start this process immediately. Your pre-qualification package cannot be approved overnight – don’t wait until the last minute.

See the Grants Gateway at http://grantsreform.ny.gov/.

• First steps.
  • Fill out the Registration Form for Administrator, have it notarized.
  • Create an organization chart that shows the head of your organization. The state has some samples here. JCRC-NY created a sample for religious schools here. Be sure to fill in the appropriate names in the boxes.
  • New applicants must request an SFS ID. Do so by completing a copy of Substitute W-9.
  • Mail the notarized Registration Form, Substitute W-9 and Organizational Chart to: Division of Budget – Grants Reform, Agency Building 1 – 5th Floor, Empire State Plaza, Albany, NY 12224.
• Tutorial. Watch the video on completing the Pre-Qualification process here.
• Written resources. The Grants Gateway website contains the definitive information. Be sure to check the required list of documents at Documents and Questions. More information can be found at the FAQs About Prequalification and the full manual.
• Assistance. Any organization unsure about how to respond to the questions should contact the Statewide Grants Reform office at grantsgatewayhelp@budget.ny.gov or (518) 474-5595. While we try to learn as much as we can, the advice given by the Statewide Grants Reform office is definitive.
• Documents. The Grants Gateway website has lots of information. You should consider their requirements and answers as the final word. A short list of the documents that organizations are required to submit include:

1. Certificate of Incorporation or equivalent document.
2. IRS 501(c)(3) determination letter. As long as your organization is seeking tax exempt status and can show that it
   has applied for a 501(c)(3) tax exemption from the IRS, then the uploading of a copy of your application form or a copy of the receipt letter from the IRS, is sufficient. They also recognize that some tax exempt organizations are not required to file for IRS 501(c)(3) recognition.Your organization will not be penalized if you do not submit its determination letter, if:
   • you are not required to have one; and
   • you write a letter attesting to the fact. For example, houses of worship and organizations incorporated pre-1969 are not required to file for 501(c)(3) recognition . Religious organizations need only provide a statement, including their official name, stating that they are a religious corporation and exempt from IRS recognition.
3. IRS 990.
   Houses of worship and some other religious corporations are not required to file an IRS 990. If your organization is not required to file an IRS 990, Religious organizations need only include a statement, including their official name, stating that you are a religious corporation and exempt from the requirement to file an IRS 990. If you do file, please include your latest IRS Form 990.
4. Audit/Reviews and Findings. In NY, organizations with revenues greater than $250,000 must provide an independently audited financial statement. Organizations with revenues of less than $250,000 but greater than $100,000, must provide a financial statement reviewed by a CPA. Organizations with revenues of less than $100,000 need only provide a copy of the most recent internal financial report.Prequalification Audit Change.
   • Previous Audit Requirement – CPA reviewed audit with management letter for organizations with revenues over $250K.
   • New Audit Requirement (3/25/2014) – Entities that are exempt by Executive Law § 172-a from submitting financial disclosure materials to the Attorney General’s Charities Bureau (such as religious organizations involved in exclusively non-secular activities) should, regardless of their annual revenue, provide their most recent internal financial report reviewed by the board.  This is the same financial disclosure requirement for prequalification that applies to organizations with revenues of less than $100,000.
5. NY State Attorney General Charities Bureau Form CHAR500 or CHAR410. Most not-for-profit organizations must file either a CHAR 410 (for newly formed entities within the first year of operations) or a recent CHAR500 with the NY State Charities Bureau. Religious organizations, as well as educational corporations that confine solicitations to their student body, alumni, faculty and trustees and their families; need only include a statement, including their official name, stating that they are a religious or an educational corporation and exempt from registration with the New York State Attorney General.
6. Board of Directors Profile. A sample profile template can be found here. This document should include board member names and affiliations, a list of the board
   committees and chairs, and a list of board officers.
7. Senior Leadership Resumes.
   Not-for-profits must upload the resumes or CV’s of their Senior Leadership team. The positions included should be Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Executive Director, President, or other high ranking officials. Individuals should upload their own resume or CV.
8. Corporate Bylaws

There are also questions covering organizational policies supporting good governance, etc. The Grants Gateway (especially the manual) website has the rationale, samples and links to other sites with further information. If you have any questions about prequalification, please go to the Grants Reform website at http://www.grantsreform.ny.gov/Grantees or contact DHSES at 1-866-837-9133.

The Grant itself

Vulnerability assessment. We expect that the “Investment Justification” will again be based on a “previously conducted vulnerability assessment.” See Getting a vulnerability assessment for more details and suggestions.

• Read and understand the Investment Justification. Download the Investment Justification from last year here. There will be some changes, but they are usually minor. You can find JCRC-NY’s guidance on each section on the “Security Grants” webpage (and below). Note: many applicants lost points last year because they did not properly respond to the questions.
• Applicant Information
• Background
• Risk: Threats, Vulnerabilities & Potential Consequences
• Target Hardening
• Milestones
• Project Management
• Impact

We expect the U.S. Department of Homeland Security to release the guidance on the program to the states on or about March 18th. We don’t expect any major changes in the requirements. New York DHSES will secure the necessary approvals and release their Request for Applications the following week.

This year’s budget includes $13 million in federal funding to help protect high-risk non-profit institutions from terrorist attacks. This is a $3 million increase over the fiscal year 2013 funding levels for the Nonprofit Security Grant Program. New York nonprofits must pre-qualify (see below), which may take several weeks (see below). While completing the pre-qualification process, organizations should assemble the materials for their Investification Justification (see here). Get started now!

New York’s new requirement

Pre-qualify with NY State. Applications from New York nonprofit organizations that have not “pre-qualified” will not be considered, so we recommend that you start this process immediately. Your pre-qualification package cannot be approved overnight – don’t wait until the last minute.

See the Grants Gateway at http://grantsreform.ny.gov/.

• Written resources. The Grants Gateway website contains the definitive information. Be sure to check the required list of documents at Documents and Questions. More information can be found at the FAQs About Prequalification and the full manual.
• Assistance. Any organization unsure about how to respond to the questions should contact the Statewide Grants Reform office at grantsgatewayhelp@budget.ny.gov or (518) 474-5595. While we try to learn as much as we can, the advice given by the Statewide Grants Reform office is definitive.
• Documents. The Grants Gateway website has lots of information. You should consider their requirements and answers as the final word. A short list of the documents that organizations are required to submit include:

1. Certificate of Incorporation or equivalent document.
2. IRS 501(c)(3) determination letter. As long as your organization is seeking tax exempt status and can show that it
   has applied for a 501(c)(3) tax exemption from the IRS, then the uploading of a copy of your application form or a copy of the receipt letter from the IRS, is sufficient. They also recognize that some tax exempt organizations are not required to file for IRS 501(c)(3) recognition.Your organization will not be penalized if you do not submit its determination letter, if:

• you are not required to have one; and
• you write a letter attesting to the fact. For example, houses of worship and organizations incorporated pre-1969 are not required to file for 501(c)(3) recognition . Religious organizations need only provide a statement, including their official name, stating that they are a religious corporation and exempt from IRS recognition.

• IRS 990. Houses of worship and some other religious corporations are not required to file an IRS 990. If your organization is not required to file an IRS 990, Religious organizations need only include a statement, including their official name, stating that you are a religious corporation and exempt from the requirement to file an IRS 990. If you do file, please include your latest IRS Form 990.
• Audit/Reviews and Findings. In NY, organizations with revenues greater than $250,000 must provide an independently audited financial statement. Organizations with revenues of less than $250,000 but greater than $100,000, must provide a financial statement reviewed by a CPA. Organizations with revenues of less than $100,000 need only provide a copy of the most recent internal financial report.

• Exceptions.
  • Religious organizations pursuing religious activity are exempt from the financial filing requirements regarding audit/reviews and findings.
    If you are a religious organization pursuing religious activity, you need only include a statement, including your official name, stating that you are a religious corporation pursuing religious activity and not required to report or file financial information with the New York State Attorney General.
  • However, religious organizations that engage in any form of secular activity (i.e. food bank, daycare, social justice advocacy, secular education, job training, conservation, after school athletics, etc.) must file through the Grants Gateway their audit/reviews or findings, consistent with their level revenues .
  • JCRC has inquired whether certain schools, exempt from filing with the New York State Attorney General, are required to file audit/reviews or findings.
• NY State Attorney General Charities Bureau Form CHAR500 or CHAR410. Most not-for-profit organizations must file either a CHAR 410 (for newly formed entities within the first year of operations) or a recent CHAR 500 with the NY State Charities Bureau. Religious organizations, as well as educational corporations that confine solicitations to their student body, alumni, faculty and trustees and their families; need only include a statement, including their official name, stating that they are a religious or an educational corporation and exempt from registration with the New York State Attorney General.
• Board of Directors Profile. A sample profile template can be found here. This document should include board member names and affiliations, a list of the board committees and chairs, and a list of board officers.
• Senior Leadership Resumes.
  Not-for-profits must upload the resumes or CV’s of their Senior Leadership team. The positions included should be Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Executive Director, President, or other high ranking officials. Individuals should upload their own resume or CV.
• Corporate Bylaws

There are also questions covering organizational policies supporting good governance, etc. The Grants Gateway (especially the manual) website has the rationale, samples and links to other sites with further information.

The Grant itself

Vulnerability assessment. We expect that the “Investment Justification” will again be based on a “previously conducted vulnerability assessment.” See Getting a vulnerability assessment for more details and suggestions.

• Read and understand the Investment Justification. Download the Investment Justification from last year here. There will be some changes, but they are usually minor. You can find JCRC-NY’s guidance on each section on the “Security Grants” webpage (and below). Note: many applicants lost points last year because they did not properly respond to the questions.

• Applicant Information
• Background
• Risk: Threats, Vulnerabilities & Potential Consequences
• Target Hardening
• Milestones
• Project Management
• Impact

Status

This year’s budget includes $13 million in federal funding to help protect high-risk non-profit institutions from terrorist attacks. This is a $3 million increase over the fiscal year 2013 funding levels for the Nonprofit Security Grant Program. We don’t know when the U.S. Department of Homeland Security will release the guidance on the program (best guess mid to late March), but we don’t expect any major changes. Get started now!

The newest requirement

Pre-qualify with NY State. Applications from New York nonprofit organizations that have not “pre-qualified” will not be considered, so start this process immediately. See the Grants Gateway at http://grantsreform.ny.gov/grantees. We requested a webinar on pre-qualification to assist you. Stay tuned.

• Documents. Here is a quick summary of the necessary documents (the official website contains the definitive information). Make sure to check the required list of documents at Documents and Questions. There is more information at FAQs About Prequalification and a full manual. You will need:

1. Certificate of Incorporation or equivalent document.
2. IRS 501(c)(3) determination letter. As long as your organization is seeking tax exempt status and can show that it
   has applied for either a 501(c)(3) or 501(c)(4) tax exemption from the IRS, then by uploading a copy of your application form or a copy of the receipt letter from the IRS, everything
   should be fine. Also, we recognize that some tax exempt organizations are not required to
   file for a 501(c)(3), so they will not be penalized for not producing this document. [JCRC comment: Houses of worship are not required to file for 501(c)(3) recognition. They should simply state, on organizational letterhead: As a religious corporation they are not required to secure an IRS 501(c)(3) determination letter.]
3. IRS 990. Houses of worship and some other religious corporations are not required to file an IRS 990. [JCRC comment: Houses of worship are not required to file for 501(c)(3) recognition. They should simply state, on organizational letterhead: As a religious corporation they are not required to file IRS Form 990.]
4. Audit/Reviews and Findings.In NY, organizations with revenues greater than $250K
   must provide an independently audited financial statement. Organizations with revenues of less than $250K but greater than $100K, must provide a financial statement reviewed by a CPA. Organizations with revenues of less than $100K need only provide a copy of the most recent internal financial report. [JCRC comment: This is a requirement, if your organization’s revenues exceed $250,000 there is no alternative. We are afraid that this will disqualify many organizations.]
5. CHAR500 or CHAR410. All not-for-profit organizations must file either a CHAR 410 (for newly formed entities within the first year of operations) or a recent CHAR 500 with the NY State
   Charities Bureau. [JCRC comment: There is a form to request an exemption (Schedule E).]
6. Board of Directors Profile. A sample profile template can be found here. This document should include board member names and affiliations, a list of the board committees and chairs, and a list of board officers.
7. Senior Leadership Resumes. Not-for-profits must upload the resumes or CVs of their Senior Leadership team. The positions included should be Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Executive Director, President, or other high ranking officials. Individuals should upload their own resume or CV.
8. Corporate Bylaws

There are also questions about governance, etc.

The Grant itself

Vulnerability assessment. We expect that the “Investment Justification” will again be based on a “previously conducted vulnerability assessment.” See Getting a vulnerability assessment for more details and suggestions.

• Read and understand the Investment Justification. Download the Investment Justification from last year here. There will be some changes, but they are usually minor. You can find JCRC-NY’s guidance on each section on the “Security Grants” webpage (and below). Note: many applicants lost points last year because they did not properly respond to the questions.

• Applicant Information
• Background
• Risk: Threats, Vulnerabilities & Potential Consequences
• Target Hardening
• Milestones
• Project Management
• Impact

Read More There will be a 2014 grant…soon

Update January 15: Today, the House voted overwhelmingly, 359-67, to approve a $1.1 trillion spending bill for the current fiscal year. It is expected to move quickly through the Senate and be signed by the President. The bill appropriates $13 million for the Nonprofit Security Grant Program, an increase of 30% over last year.

Update January 14: Congress filed the omnibus appropriations bill late yesterday, including funding for the Nonprofit Security Grant Program. The bill will be debated over the weekend.

Thanks to the incredible work of a coalition led by The Jewish Federations of North America/JFNA (with JCRC-NY and UJA-Federation playing active roles) there is likely to be another round of the Nonprofit Security Grant Program (NSGP). The JFNA Washington Office, directed by William Daroff, and its Senior Director, Legislative Affairs, Rob Goldberg deserve our most heartfelt gratitude.

For those who want the gory details: The House and Senate Appropriations Committees continue work to complete the FY14 Omnibus Appropriations bills before the current Continuing Resolution (CR) expires on January 15th. As has been the case over the past few years, it is doubtful that they will complete their work before the deadline, so there is likely to be another, short CR, giving Congress additional time to debate and vote (after all, the Omnibus bills cover virtually the entire federal budget). According to reports as of January 8th, the DHS budget was not yet approved, but is largely completed. Once the DHS budget is approved, our Washington champions will learn how much was allocated for the NSGP.

Appropriators on both sides of the aisle and chambers have pressed for a clean bill that does not include divisive partisan policy riders.  However, once the bill is filed and details emerge there are likely to be calls for amendments to diminish or obstruct implementation of Obamacare, EPA rules, and Wall Street protections or support anti-abortion policies (more than 130 such policy riders that have been mentioned, including aid for houses of worship damaged by Superstorm Sandy). There also remain, especially in the House, a number of conservatives who would still prefer passing a year-long CR at the lower FY13 spending level.

Get Ready

We strongly urge organizations contemplating applying for a grant to immediately take steps to deal with some of the details of the application package:

• Pre-qualify with NY State. Applications from New York nonprofit organizations that have not “pre-qualified” will not be considered, so start this process immediately. There are five parts of this process so we strongly urge you to start now because it may take some time. We will schedule a webinar on pre-qualification in the near future.

Effective August 1, 2013, not-for-profit organizations must be prequalified in order to do business with New York State (i.e., to receive a grant). In order to prequalify, not-for-profit organizations must submit an online Prequalification Application through the Grants Gateway. The Prequalification Application is comprised of five components to gauge your organizational structure and the types of services you provide. The required forms and document uploads are all part of the Document Vault. Resources to complete the application and associated document vault can be found in the Quick Links Section of the Grants Gateway website: http://grantsreform.ny.gov/Grantees.

• Vulnerability assessment. We expect that the “Investment Justification” will again be based on a “previously conducted vulnerability assessment.” See Getting a vulnerability assessment for more details and suggestions.
• Read and understand the Investment Justification. Download the Investment Justification from last year here. There will be some changes, but they are usually minor. You can find JCRC-NY’s guidance on each section on the “Security Grants” webpage (and below). Note: many applicants lost points last year because they did not properly respond to the questions.

• Applicant Information
• Background
• Risk: Threats, Vulnerabilities & Potential Consequences
• Target Hardening
• Milestones
• Project Management
• Impact Read More Prospects look good for a 2014 grant

The US Department of Homeland Security announced the winners of the 2013 NSGP and New York did better than ever.

This year, New York State awardees will have to do additional paperwork and we realize that  the requirements may be inappropriate for some of the grantees. JCRC reached out to Gov. Cuomo’s office to request alternatives. Stay tuned. Meanwhile, if you have any questions about prequalification, please go to the Grants Reform website at http://www.grantsreform.ny.gov/ or contact Valerie Bloomer at (518) 242-5099 or via email at vbloomer@dhses.ny.gov.

The NY application package is posted here. (Thank you Val) FY2013 UASI NSGP Request for Applications FY2013 NSGP Investment Justification Template Instructions FY2013 NSGP Investment Justification Template Grantee Responsibility Questionnaire E-Grants Registration E-Grants tutorial NFP 2013 All NY applicants must submit their materials via E-Grants by 11:59 PM on June 10, 2013.

1. Check this blog and www.jcrcny.org/securitygrants often. We update existing and create additional materials. Find valuable additional assistance and suggestions at JFNA’s homeland security web page (registration required). 
2. Webinar. Click here to view a recording of the JCRC Webinar on the Nonprofit Security Grant Program application process here and the slides here.
3. Nonprofit Security Grant Checklist 2013. The checklist is a step-by-step guide to help you complete the application package. Download it here.
4. NY required attachments. This year applicants are required to submit a number of additional forms. Find out more here.
5. Mission statement. Applicants will be required to upload their organizational mission statements along with theirInvestment Justification. We haven’t checked this, but it is likely that organizations that have not attached their mission statements will not be considered for a grant. Fear not. We posted What is a mission statement? to guide organizations without a mission statement.

The recording or the 5/28/2013 webinar will be posted soon at www.jcrcny.org/securitygrants. The NY package should be posted here on Wednesday. If you are impatient, here are the documents (Thank you Val): FY2013 UASI NSGP Request for Applications Grantee Responsibility Questionnaire E-Grants tutorial NFP 2013 Investment Justification 2013

Download the 2013 JCRC-NY Nonprofit Grant Checklist here.